People v. Casido
REITERATIONFacts
1. The Antecedents: Accused-appellants William Casido and Franklin Alcorin were convicted of crimes. Subsequently, they were granted conditional pardons by the President. However, these pardons were issued while their appeal was still pending before the Supreme Court, rendering them void. 2. Procedural History: The case reached the Supreme Court on appeal. During the pendency of this appeal, the accused-appellants were granted conditional pardons. The Supreme Court, in a prior resolution, declared these pardons void and directed the re-arrest and re-confinement of the accused-appellants. The Court also required the Presidential Committee for the Grant of Bail, Release, and Pardon to show cause why they should not be held in contempt for processing the pardon applications despite the pending appeal. Subsequently, it was revealed that the accused-appellants had also applied for and been granted amnesty. The Office of the Solicitor General argued that the amnesty rendered the issue of the premature pardon moot. 3. The Petition: This resolution addresses the explanation provided by the Secretariat of the Presidential Committee for the Grant of Bail, Release, and Pardon regarding the circumstances of the void pardons, and the implications of the subsequent grant of amnesty. The Court ultimately ruled that while the pardon was void due to being granted before final judgment, the amnesty granted was valid and justified the release of the accused-appellants. The members of the Presidential Committee and its Secretariat were admonished for their lack of diligence.
Issue(s)
Whether the conditional pardons granted to the accused-appellants were valid. Whether the grant of amnesty to the accused-appellants rendered the issue of the premature pardon moot.
Ruling
The Court ruled that the conditional pardons granted were void. However, the grant of amnesty was valid and rendered the issue of the premature pardon moot. The case was dismissed with costs de officio. The Members of the Presidential Committee for the Grant of Bail, Release, or Pardon and its Secretariat were admonished to exercise utmost care and diligence.
Ratio Decidendi
On the validity of the conditional pardons: The Court reiterated that conditional pardons, like parole, can only be granted after conviction by final judgment, as mandated by Section 19, Article VII of the Constitution. The pardon in this case was granted on January 19, 1996, while the appeal was still pending, meaning there was no final judgment of conviction. Therefore, the conditional pardons were void ab initio. The Court found the explanation of the Secretariat regarding their unawareness of this constitutional and jurisprudential requirement to be unsatisfactory, bordering on the absurd, especially given their own requirement for the filing of motions to withdraw appeals. On the effect of the amnesty grant: The Court agreed with the Office of the Solicitor General that the grant of amnesty rendered the issue of the premature pardon moot. The Court distinguished amnesty from pardon, citing Barrioquinto v. Fernandez. Amnesty is a public act granted by the Chief Executive with the concurrence of Congress to classes of persons who may have committed political offenses, and it abolishes the offense itself, making the person stand as if no offense was committed. Unlike pardon, which is a private act and requires pleading and proof, amnesty is judicially noticed. The amnesty granted under Proclamation No. 347, which was concurred in by Congress, was valid and extinguished the criminal liability for acts committed in pursuit of political beliefs, thus justifying the release of the accused-appellants.
Main Doctrine
A conditional pardon granted during the pendency of an appeal is void. However, amnesty granted to classes of persons for political offenses, which is a public act, extinguishes criminal liability and restores civil rights, and may be granted before or after conviction. The grant of amnesty to the accused-appellants rendered moot the issue of the premature pardon.