People v. Taruc
REITERATIONFacts
1. The Antecedents: Francisco Taruc was charged with murder for the killing of Emelito Sualog. The Information alleged that on or about November 8, 1998, in Brgy. Puting Buhangin, Orion, Bataan, the accused, with intent to kill, treachery, and evident premeditation, willfully, unlawfully, and feloniously attacked and shot Emelito Sualog with a .45 caliber firearm on different parts of his body, inflicting mortal wounds that directly and immediately caused his death. 2. Procedural History: The Regional Trial Court (RTC) of Bataan, Branch 3, convicted Francisco Taruc of murder and sentenced him to death, ordering him to pay civil and actual damages. The case was automatically elevated to the Court of Appeals for review. During the pendency of the appeal, Francisco Taruc escaped from the Bataan Provincial Jail on August 23, 2002. Despite his escape, the Court of Appeals affirmed the conviction with modification, reducing the penalty from death to reclusion perpetua due to Republic Act No. 9346, and ordered payment of damages. Accused-appellant, through his counsel from the Public Attorney's Office (PAO), filed a Notice of Appeal to the Supreme Court. 3. The Petition: This case is before the Supreme Court via a Petition for Review on Certiorari under Rule 45 of the Rules of Court. The core issue is whether the accused-appellant, having escaped from prison and remained at large, has lost his right to appeal his conviction. The Court notes that the accused failed to be present at the promulgation of the RTC judgment and did not surrender within the prescribed period, thus losing his remedies. Despite the mandatory review of death penalty cases by the Court of Appeals, the Supreme Court, citing established jurisprudence, holds that an accused who escapes from prison waives their right to appeal unless they surrender or submit to the court's jurisdiction.
Issue(s)
Whether an accused who escapes from prison loses their right to appeal. Whether the escape of the accused-appellant precluded the Court of Appeals from exercising its review jurisdiction in a case involving a death penalty, and whether the accused-appellant's escape constituted a waiver of his right to appeal. On the accused-appellant's conduct of remaining at large throughout the proceedings before the RTC, CA, and Supreme Court.
Ruling
The Supreme Court dismissed the appeal. The Court held that by escaping from prison, the accused-appellant impliedly waived his right to appeal and lost his standing in court. The Court remanded the records to the trial court for the issuance of the mittimus.
Ratio Decidendi
On the issue of waiver of the right to appeal due to escape: The Court reiterated the principle that the right to appeal is granted for the benefit of the accused and can be waived, either expressly or by implication. Citing People v. Ang Gioc, the Court stated that when an accused flees after the case has been submitted for decision, they are deemed to have waived their right to appeal. The accused-appellant's escape from jail meant he was not present at the promulgation of the RTC Decision and failed to surrender within the prescribed 15-day period, thereby depriving him of any remedy against the judgment of conviction. The Court emphasized that by putting himself beyond the reach of legal processes, the accused-appellant demonstrated contempt for the law and could not expect relief from the appellate court. On the Court of Appeals' jurisdiction despite the escape, and on whether the escape constituted a waiver: The Court acknowledged that while the escape generally deprives an accused of the right to appeal, it did not preclude the Court of Appeals from exercising its review jurisdiction because the penalty imposed by the trial court was death. The mandatory nature of automatic review in death penalty cases compelled the appellate court to proceed with the review. However, this did not negate the consequence of the escape on the accused's right to actively pursue his appeal. The Court found the accused-appellant's conduct of remaining at large throughout the proceedings before the RTC, CA, and Supreme Court to be intolerable. Such behavior, which kept him out of the reach of justice while hoping to render the judgment nugatory, did not warrant leniency. The Court concluded that the accused-appellant could not audaciously hope for his appeal to succeed while remaining a fugitive from justice.
Main Doctrine
An accused who escapes from prison waives their right to appeal and loses their standing in court, unless they surrender or submit to the court's jurisdiction within the prescribed period.