People v. Rocha
REITERATIONFacts
The Antecedents: On May 12, 1994, an Information was filed against Emmanuel Rocha alias Nopoy, Ruel Ramos alias Aweng, Romeo Trumpeta, and Eustaquio Cenita for Robbery with Homicide. The Information alleged that on September 28, 1993, in Quezon City, the accused, armed with guns and in conspiracy, robbed the Bank of the Philippine Islands (BPI) by opening fire at security guards Roger Tarroquin and Tito Homeress, causing their deaths, and thereafter taking two duffle bags containing ₱1.5 million pesos and firearms. Procedural History: The Regional Trial Court (RTC) of Quezon City, Branch 215, found Rocha, Ramos, Trumpeta, and Cenita guilty of Robbery with Homicide and sentenced them to reclusion perpetua. The RTC also ordered them to pay civil indemnity to the heirs of the victims and to BPI. Trumpeta and Cenita subsequently withdrew their appeals. The case was transferred to the Court of Appeals (CA) pursuant to People v. Mateo. The CA affirmed the RTC decision, sentencing Rocha and Ramos to reclusion perpetua and ordering them to pay civil indemnity. Rocha and Ramos appealed to the Supreme Court. The Petition: Accused-appellants Rocha and Ramos filed separate Motions to Withdraw Appeal, citing their long detention and their intention to apply for parole and executive clemency. The People of the Philippines, through the Solicitor General, opposed the motions, arguing that appeals in cases with reclusion perpetua are mandatory and cannot be waived.
Issue(s)
Whether the motions to withdraw appeal of accused-appellants Rocha and Ramos should be granted. Whether appeals in cases where the penalty imposed is reclusion perpetua are subject to mandatory review by the Supreme Court.
Ruling
The Supreme Court GRANTED the respective Motions to Withdraw Appeal of accused-appellants Emmanuel Rocha and Ruel Ramos. The Court of Appeals Decision dated March 31, 2006, in CA-G.R. CR-H.C. No. 01765, was deemed FINAL AND EXECUTORY.
Ratio Decidendi
On the withdrawal of appeal: Since the review of the case was not mandatory, the rule that neither the accused nor the courts can waive a mandatory review is not applicable. Consequently, the separate motions to withdraw appeal filed by accused-appellants Rocha and Ramos could be validly granted. The Court emphasized that the granting of a Motion to Withdraw Appeal is addressed to the sound discretion of the Court. In this instance, there was no showing that the accused-appellants had already applied for parole at the time of filing their motions, only that they intended to do so. The Court also noted that the People of the Philippines failed to substantiate their claim that the withdrawal was a scheme to evade the penalty or trifle with the judicial system, especially since the Court of Appeals could enter judgment in reclusion perpetua cases without further Supreme Court review. Furthermore, the Court stated that it cannot preempt the exercise of executive clemency, which is an executive function, by denying the motions to withdraw appeal. The Court deferred to the President's prerogative in granting clemency. On the mandatory review of cases with reclusion perpetua: The Court clarified that the mandatory review by the Supreme Court is exclusively required for cases where the penalty imposed is death. The constitutional provision cited in People v. Mateo (Article VIII, Section 5(2)(d)) grants the Supreme Court jurisdiction over cases with reclusion perpetua or higher, but it does not mandate automatic review for such cases. Prior to Mateo, cases with reclusion perpetua were brought before the Supreme Court via a notice of appeal, unlike death penalty cases which were subject to automatic review. The amendments to the Rules of Court following Mateo maintained this distinction, requiring a notice of appeal for reclusion perpetua cases and continuing automatic review only for death penalty cases. Therefore, the review by the Supreme Court in this case, where the penalty imposed was reclusion perpetua, was not mandatory.
Main Doctrine
The mandatory review by the Supreme Court is required only for cases where the penalty imposed is death. For cases where the penalty imposed is reclusion perpetua or life imprisonment, a review is conducted only when the accused files a notice of appeal, and thus, the accused may validly withdraw their appeal.