Teope v. People
REITERATIONFacts
The Antecedents: Florita Teope was charged with two counts of violating Batas Pambansa Bilang 22 (B.P. 22). Following the prosecution's presentation of evidence, Teope filed a Demurrer to the Evidence, which the Regional Trial Court (RTC) denied. Subsequently, Teope failed to appear for scheduled hearings, leading to the forfeiture of her bail bonds and a declaration that she was a fugitive from justice. Despite these events, her counsel continued to file various motions. Procedural History: After the denial of her Demurrer to the Evidence, Teope's counsel filed a Notice of Appeal from this denial, which the RTC also denied, citing her status as a fugitive. Teope then filed a petition for mandamus with the Court of Appeals, seeking to compel the RTC to give due course to her appeal. The Court of Appeals dismissed this petition, and a subsequent motion for reconsideration was also denied. This dismissal and denial are the subject of the current petition. The Petition: This case is a petition for review on certiorari seeking to overturn the Court of Appeals' dismissal of Teope's petition for mandamus. Teope argues that the Court of Appeals erred in dismissing her petition. The Supreme Court, however, found that Teope, by escaping and remaining at large, lost her standing in court and forfeited her right to avail of remedies against the judgment, including the right to appeal. Therefore, mandamus would not lie to compel an appeal that she was barred from pursuing.
Issue(s)
Whether a convicted accused who has jumped bail and remains a fugitive from justice is entitled to the remedy of appeal and can compel the same via a petition for Mandamus.
Ruling
The Supreme Court denied the petition for review and affirmed the Decision and Resolution of the Court of Appeals. The Court held that petitioner, having lost her standing in court due to her fugitive status, was barred from availing of remedies against the RTC's judgment, including the right to appeal. Consequently, the petition for mandamus to compel the grant of due course to her appeal could not prosper.
Ratio Decidendi
On the Single Issue: The Court held that Teope is barred from availing of the remedies allowed by the Rules of Court against the judgment of conviction because she escaped after her arraignment and remains at large. Under Section 6, Rule 120 of the Revised Rules of Criminal Procedure, an accused who fails to appear at the promulgation of a judgment of conviction without justifiable cause loses the remedies available against said judgment. While the Rules allow an accused fifteen days from the promulgation to surrender and file a motion for leave to avail of remedies, Teope failed to do so and continued to evade the court's jurisdiction. Applying the doctrine in People v. Mapalao (1991), the Court emphasized that once an accused jumps bail or flees, they lose their standing in court; seeking relief from the court is deemed waived until they submit to its jurisdiction. Consequently, the petition for Mandamus cannot prosper because Mandamus only lies to compel the performance of a ministerial duty where the petitioner has a well-defined and certain right. Since Teope lost her right to appeal by her status as a fugitive, there was no clear legal right to compel the RTC to grant the appeal, and the RTC's denial of the Notice of Appeal was proper.
Main Doctrine
An accused who escapes from confinement or jumps bail loses their standing in court and waives any right to seek relief from the court, including the right to appeal, unless they surrender or submit to the court's jurisdiction.