People v. Escaño
REITERATIONFacts
The Antecedents: Julian Deen Escaño, Virgilio Usana, and Jerry Lopez were charged with violation of Section 4, Article II of Republic Act No. 6425, as amended, in Criminal Case No. 95-936. Escaño and Usana were also charged with violation of Presidential Decree No. 1866 in Criminal Cases Nos. 95-937 and 95-938, respectively. The cases were consolidated and jointly tried. Procedural History: The Regional Trial Court (RTC) of Makati City, Branch 64, convicted all three accused in Criminal Case No. 95-936. Escaño was also convicted in Criminal Case No. 95-937, and Usana in Criminal Case No. 95-938. Escaño initially filed a Notice of Appeal but subsequently withdrew it, which was granted by the RTC. The Petition: Accused Julian Deen Escaño filed a Manifestation and Motion praying that the Supreme Court's Decision dated January 28, 2000, which acquitted accused-appellants Virgilio T. Usana and Jerry C. Lopez in Criminal Case No. 95-936, be applied to him. He invoked Section 11(a), Rule 122 of the New Rules on Criminal Procedure, arguing that the factual findings in the appellate court's decision equally supported his acquittal due to unproven elements of the offense.
Issue(s)
Whether the acquittal of co-accused Virgilio T. Usana and Jerry C. Lopez in Criminal Case No. 95-936, based on reasonable doubt, should extend to accused Julian Deen Escaño despite his withdrawal of appeal, considering Section 11(a), Rule 122 of the New Rules on Criminal Procedure.
Ruling
The Supreme Court GRANTED the Manifestation and Motion. It REVERSED and SET ASIDE the decision of the RTC dated May 30, 1997, insofar as Criminal Case No. 95-936 is concerned with regard to accused Julian Deen Escaño. The Court rendered a new judgment ACQUITTING him on the ground of reasonable doubt and ORDERED his immediate release from confinement unless his further detention is justified for any lawful ground. The Director of the Bureau of Corrections was directed to report the release within five (5) days from notice.
Ratio Decidendi
On the issue of applying the acquittal of co-accused to the movant despite withdrawal of appeal: The Court found merit in the Manifestation and Motion. It held that consistent with its rulings in several cases, the acquittal of Usana and Lopez based on reasonable doubt should benefit movant Escaño, notwithstanding the fact that he withdrew his appeal. The Court emphasized the principle enshrined in Section 11(a), Rule 122 of the New Rules on Criminal Procedure, which states that an appeal taken by one or more of several accused shall not affect those who did not appeal, except insofar as the judgment of the appellate court is favorable and applicable to the latter. Escaño argued that the Supreme Court's decision acquitting his co-accused was applicable and favorable to him because the factual findings therein supported the conclusion that not all elements of the offense were proven, thus no criminal liability could be imputed to him. The Office of the Solicitor General manifested no objection to the motion, recommending that it be given due course. The Court agreed with Escaño's contention that the favorable judgment on reasonable doubt should extend to him, even with his withdrawal of appeal, as the underlying factual basis for the acquittal was equally applicable to his situation. The Court cited previous cases such as People v. Tujon, People v. Perez, People v. Fernandez, People v. Ferras, and People v. Fronda to support its consistent application of this principle. Therefore, the Court granted the motion, reversing the RTC's conviction of Escaño in Criminal Case No. 95-936 and acquitting him on the ground of reasonable doubt.
Main Doctrine
The acquittal of co-accused based on reasonable doubt may benefit an accused who withdrew his appeal, applying the principle that an appeal taken by one or more of several accused shall not affect those who did not appeal, except insofar as the judgment of the appellate court is favorable and applicable to the latter.