People v. Maquilan
REITERATIONFacts
The Antecedents: Accused-appellant Emma Maquilan was convicted by the Regional Trial Court of Sindangan, Zamboanga del Norte (Branch 11) for drug-pushing in violation of R.A. No. 6425, as amended. She was sentenced to suffer the penalty of reclusion perpetua and the marijuana cigarettes and seeds seized from her were ordered destroyed. Procedural History: Following her conviction, accused-appellant filed a notice of appeal, forwarding the case records to the Supreme Court. However, before the Court could act on the appeal, she moved to withdraw it, stating her intention to file a petition for a writ of habeas corpus to secure her release for the sake of her children. The Court required comments from the Solicitor General and her counsel. Subsequently, it was revealed that accused-appellant had been released from prison by order of the Regional Trial Court of Pasig City (Branch 71) in a habeas corpus case. The Supreme Court then required the RTC judge to show cause why he should not be held in contempt for ordering the release while the appeal was pending. The Petition: Accused-appellant, through counsel, filed a handwritten letter to withdraw her appeal, indicating a subsequent petition for a writ of habeas corpus. In the habeas corpus petition filed with the Regional Trial Court of Pasig City, she allegedly misrepresented that her conviction was by a final decision, omitting the fact that her appeal was still pending before the Supreme Court. The respondent in the habeas corpus case, the Superintendent of the Correctional Institute for Women, interposed no objection. The Supreme Court, in its resolution, denied the motion to withdraw the appeal and directed the rearrest of accused-appellant, also requiring her, her counsel, and the Superintendent of the Correctional Institute for Women to show cause why they should not be held in contempt for misrepresenting the status of the case to the RTC.
Issue(s)
Whether the withdrawal of the appeal should be granted, and whether the issuance of a writ of habeas corpus and the subsequent release of the accused-appellant were proper while an appeal was pending. Whether the RTC judge, the accused-appellant, her counsel, and the Superintendent of the Correctional Institution for Women committed contempt of court for actions related to the habeas corpus order and the accused-appellant's release.
Ruling
The motion to withdraw appeal is DENIED. The Bureau of Corrections is DIRECTED to effect the rearrest of accused-appellant Emma Maquilan within sixty (60) days from notice and reconfine her at the Correctional Institute for Women. Further action on the appeal is held in abeyance pending her rearrest. Accused-appellant Emma Maquilan, Atty. Editha C. Pio, and Rachel D. Ruelo are REQUIRED to SHOW CAUSE within ten (10) days from notice why they should not be held in contempt for misrepresenting the status of the criminal case to the RTC of Pasig City.
Ratio Decidendi
On the withdrawal of appeal and the propriety of the habeas corpus writ: The Court held that the use of the high prerogative writ of habeas corpus presupposes a final judgment by virtue of which an accused is detained for the service of a sentence. In this case, the accused-appellant's appeal was still pending before the Supreme Court, meaning the judgment of conviction had not yet become final. Therefore, the RTC of Pasig City had no jurisdiction to issue the order granting the writ of habeas corpus and ordering the release of the accused-appellant. The release of the accused-appellant constituted unlawful interference with the proceedings of the Supreme Court. The RTC judge was misled by the accused-appellant's misrepresentation that the decision was final, rendering the order void. The Court cited People v. Bacang and People v. Salle, Jr., which established that pardon or release during the pendency of an appeal is improper and that those responsible may be administratively liable. The Court reiterated that the conviction by final judgment limitation under the Constitution prohibits the grant of pardon or release during the pendency of an appeal unless the appeal is withdrawn. The Court's denial of the motion to withdraw the appeal and the directive for rearrest underscore the principle that appellate proceedings must be respected and cannot be circumvented by post-conviction remedies based on erroneous premises. On the contempt charge: The Court required the accused-appellant, her counsel in the habeas corpus case, and the Superintendent of the Correctional Institution for Women to show cause why they should not be held in contempt. This action stems from the misrepresentation made to the RTC of Pasig City regarding the finality of the conviction in Criminal Case No. S-2191. The accused-appellant falsely stated that she was in custody by reason of a final decision, omitting any mention of her pending appeal. The respondent Superintendent, by interposing no objection to the petition without verifying the status of the appeal, also contributed to the improper release. Such actions constitute an affront to the jurisdiction of the appellate court and an obstruction of justice, warranting an inquiry into potential contemptuous conduct.
Main Doctrine
The use of the writ of habeas corpus presupposes a final judgment; its use to secure release during the pendency of an appeal constitutes unlawful interference with court proceedings and renders the issuing court's order void. Those responsible for such release may be held administratively liable and cited for contempt.