Lanestosa v. Santamaria
REITERATIONFacts
1. The Antecedents: Petitioners Fausta Lanestosa and Bernabe Lames were convicted in criminal case No. 8142 of the Court of First Instance of Iloilo for the crime of resistance to authority. They were sentenced to one year and eight months, and four years imprisonment, respectively. 2. Procedural History: Nine days after being informed of the judgment, the petitioners voluntarily waived their right to appeal and requested immediate transfer to Bilibid Prison. The respondent judge, after personally hearing them, issued an order admitting their waiver and directing their commitment. Subsequently, the petitioners filed a motion to reconsider this order, seeking to withdraw their waiver and have their appeal admitted. The respondent judge denied this motion, holding that he lacked jurisdiction to admit the appeal after the waiver and commitment order had been issued. 3. The Petition: This is a mandamus proceeding instituted by Fausta Lanestosa and Bernabe Lames, seeking an order directed to the Honorable Francisco Santamaria, Judge of First Instance of Iloilo, commanding him to admit their appeal. The petitioners argue that their waiver was made in despair due to their inability to post bond and that they did not fully realize the consequences. They contend the court has jurisdiction to reconsider its order and admit the appeal as the legal period had not yet expired. The Supreme Court, however, held that the waiver, coupled with the voluntary petition for immediate commitment and the subsequent order of commitment, constituted compliance with the judgment, terminating the trial judge's jurisdiction and precluding the reinstatement of the right to appeal.
Issue(s)
Whether the respondent judge committed a grave abuse of discretion amounting to lack of jurisdiction in refusing to admit the appeal filed by the petitioners. Whether the waiver of the right to appeal, coupled with a petition for immediate commitment and the court's order thereon, constitutes a voluntary compliance with the judgment that divests the trial court of jurisdiction to reinstate the appeal.
Ruling
The petition for mandamus is denied. The Supreme Court held that the waiver of the right to appeal, accompanied by a voluntary petition for immediate commitment to Bilibid Prison and the lower court's order admitting the waiver and ordering commitment, amounts to a voluntary compliance with the judgment, which terminates the trial judge's jurisdiction over the case. Consequently, the Supreme Court cannot order the judge to reinstate the petitioners' right to appeal.
Ratio Decidendi
On the issue of whether the respondent judge committed a grave abuse of discretion amounting to lack of jurisdiction in refusing to admit the appeal: The Supreme Court held that the respondent judge did not commit a grave abuse of discretion. The petitioners, nine days after being informed of the judgment, voluntarily and in writing waived their right to appeal and prayed for immediate commitment to Bilibid Prison. The court personally heard them before issuing the order admitting their waiver and ordering their commitment. This personal hearing and confirmation of their waiver indicated they had ample time to ponder and consult before making such a decision. Their subsequent petition to be sent to Bilibid Prison at the earliest opportunity demonstrated they were perfectly aware of the scope and meaning of their waiver. Therefore, when the respondent judge granted their petition and ordered their immediate commitment, the execution of the judgment began, and the judge ceased to have jurisdiction over the same. On the issue of whether the waiver of the right to appeal, coupled with a petition for immediate commitment and the court's order thereon, constitutes a voluntary compliance with the judgment that divests the trial court of jurisdiction to reinstate the appeal: The Supreme Court affirmed that such actions constitute voluntary compliance with the judgment. Citing Gregorio vs. Director of Prisons, the Court reiterated that a sentence in a criminal case becomes final either by the lapse of the fifteen-day period for appeal or by compliance with the terms of the sentence. In this case, the petitioners' waiver, their petition for immediate commitment, and the court's order thereon constituted compliance. The Court further emphasized that as a general rule, once a defendant has entered upon the execution of a valid sentence, the court cannot set it aside and render a new sentence, as this would place the defendant in double jeopardy. Therefore, the trial judge's jurisdiction over the case ended upon the commencement of the execution of the sentence, making it impossible to reinstate the right to appeal.
Main Doctrine
A waiver of the right to appeal, accompanied by a voluntary petition for immediate commitment to prison and the court's order admitting such waiver and ordering commitment, constitutes voluntary compliance with the judgment, terminating the trial judge's jurisdiction and precluding reinstatement of the right to appeal.