People v. Reyes
REITERATIONFacts
The Antecedents: On December 22, 1994, Imelda B. Brutas was invited to the house of Donel Go (appellant) in Albay. There, Go and Val De Los Reyes (Val) forced her to drink beer, causing her to feel dizzy. While in this state, Val raped her against her will. Subsequently, Go raped her while Val held her hands and covered her mouth. Val then raped her a second time with Go's assistance. Criminal complaints for rape were filed against both Go and Val. Procedural History: Only Go was initially arrested. He pleaded not guilty but jumped bail during the presentation of prosecution evidence. He was tried in absentia, and on June 25, 1997, the Regional Trial Court (RTC) convicted him of two counts of rape, sentencing him to death. The case was elevated for automatic review. Val was later arrested and convicted, but the Supreme Court (SC) remanded his case in 2002 because the RTC had merely adopted transcripts from Go's trial instead of taking oral testimony. Val was eventually re-convicted, and the Court of Appeals (CA) modified his sentence to reclusion perpetua. The Appeal: While Val's separate appeal proceeded, the automatic review of Go's conviction was held in abeyance. Go has remained at large since jumping bail. The Supreme Court now addresses whether Go's appeal should be entertained or dismissed given his status as a fugitive from justice.
Issue(s)
Whether the appeal of an accused who jumped bail and remains at large should be dismissed.
Ruling
The appeal is DISMISSED.
Ratio Decidendi
On Issue 1: The Supreme Court held that Donel Go lost his standing in court by jumping bail and remaining a fugitive. Applying the doctrine in 'Villena v. People', the Court emphasized that an accused who evades the jurisdiction of the court is deemed to have waived any right to seek relief. Under Section 8, Rule 124 of the Rules of Court, the appellate court has the authority to dismiss an appeal motu proprio if the appellant jumps bail during the pendency of the appeal. The Court noted that the right to appeal is not a natural right but a statutory privilege that must be exercised in strict compliance with the Rules. Although the 'People v. Mateo' ruling generally requires an intermediate review by the CA for cases involving the death penalty, the Court found a remand unnecessary in this instance. Since Go is a fugitive, the CA would be legally constrained to dismiss the appeal anyway, making a remand a futile exercise in procedural redundancy.
Main Doctrine
The right to appeal is a mere statutory privilege and may be exercised only in the manner and in accordance with the provisions of the law. An accused who jumps bail or escapes from confinement is considered a fugitive from justice and loses standing in court. This loss of standing results in a waiver of the right to seek affirmative relief, including the right to have a conviction reviewed by a higher court. Consequently, under Rule 124, Section 8 of the Rules of Court, the appellate court has the discretion to dismiss the appeal motu proprio if the appellant escapes or jumps bail during the pendency of the appeal.