Declarador v. Gubaton
REITERATIONFacts
The Antecedents: Frank Bansales, born June 3, 1985, a student, stabbed his teacher, Yvonne Declarador, 15 times, causing her death. An Information for murder was filed, alleging evident premeditation and abuse of superior strength. Procedural History: The Regional Trial Court (RTC), Roxas City, Branch 14, found Bansales guilty of murder. However, considering his minority (17 years old at the time of the offense), the RTC suspended his sentence and ordered his commitment to the Regional Rehabilitation Center for Youth, pursuant to P.D. 603 (Child and Youth Welfare Code) and A.M. No. 02-1-18-SC (Rule on Juveniles in Conflict with the Law). The Petition: Rennie Declarador, the surviving spouse of the deceased, filed a Petition for Certiorari, assailing the portion of the RTC decision suspending the sentence and committing Bansales to the rehabilitation center. Petitioner argued that Bansales was disqualified from availing the suspended sentence benefit as murder is punishable by reclusion perpetua to death.
Issue(s)
Whether petitioner has legal standing to file the petition. Whether the Court should take cognizance of the petition filed directly before it, bypassing the Court of Appeals. Whether the respondent court committed grave abuse of discretion amounting to excess or lack of jurisdiction in ordering the suspension of the sentence of respondent Bansales and his commitment to the Regional Rehabilitation Center for the Youth.
Ruling
The petition is granted. The Order of the respondent Judge suspending the sentence of respondent Frank Bansales is NULLIFIED.
Ratio Decidendi
On the issue of legal standing: The petitioner, as the surviving spouse of the deceased and the offended party, possesses sufficient legal personality to file the instant special civil action for certiorari. This aligns with the liberal construction of the Rules of Court to promote their objectives. Furthermore, the Office of the Solicitor General (OSG) filed a comment and joined the petitioner's plea, reinforcing the validity of the petition. On the issue of bypassing the Court of Appeals: While the general rule dictates that petitions for certiorari assailing RTC orders should be filed with the Court of Appeals, direct invocation of the Supreme Court's original jurisdiction is permissible under exceptional circumstances. In this case, considering the nature and importance of the issues involving a juvenile and the application of the Rule on Juveniles in Conflict with the Law, and in the interest of speedy justice, the Court resolved to take cognizance of the petition directly filed before it to avoid further litigation. On the grave abuse of discretion: The respondent court committed grave abuse of discretion amounting to excess of jurisdiction. The charge against Bansales was murder, which, under Article 248 of the Revised Penal Code, as amended by Republic Act No. 7659, is punishable by reclusion perpetua to death. Article 192 of P.D. No. 603, as amended, and Section 32 of A.M. No. 02-1-18-SC explicitly state that the benefits of a suspended sentence shall not apply to a youthful offender who is convicted of an offense punishable by death or life imprisonment or reclusion perpetua. The term "punishable" refers to the imposable penalty, not the actual penalty imposed. Therefore, Bansales was disqualified from availing the suspended sentence, and the trial court's order to suspend his sentence was erroneous.
Main Doctrine
A youthful offender convicted of an offense punishable by death, reclusion perpetua, or life imprisonment is disqualified from availing the benefits of a suspended sentence, regardless of the penalty actually imposed by the trial court. The disqualification is based on the imposable penalty for the crime charged, not the imposed penalty.