People v. Quebral
REITERATIONFacts
The Antecedents: The appellant, Francisco Quebral y Arcilla, along with three unapprehended individuals, was accused of robbery in band. The information alleged that the accused and his companions, armed with firearms, conspired to forcibly take jewelry and cash totaling P530 from Antonio Sy and Domingo Tan by means of intimidation, threatening to shoot them if their demands were not met. Procedural History: The accused pleaded not guilty upon arraignment. During the trial, after the prosecution rested, the accused moved to withdraw his plea of not guilty and substitute it with a plea of guilty. The motion was granted, and the accused voluntarily entered a guilty plea. The trial court found him guilty as charged and imposed an indeterminate sentence, ordered him to indemnify the offended party, and to pay costs. The sentence was reduced to writing, signed, and read to the accused, who then commenced serving his sentence. The Petition: Two weeks after commencing his sentence, the accused, through a new attorney, moved to withdraw his guilty plea, reinstate his not guilty plea, reopen the case, and present evidence. The trial court denied this motion, citing that the sentence had become final under Section 7 of Rule 116 of the Rules of Court because the accused had begun serving it. Subsequently, the accused filed a notice of appeal, which was approved by the court.
Issue(s)
Whether the appellate court has jurisdiction to entertain an appeal when the sentence has already commenced to be served. Whether the trial court erred in denying the motion to withdraw the plea of guilty after the accused had commenced serving his sentence.
Ruling
The appeal is dismissed for lack of jurisdiction. The Supreme Court held that the sentence had become final and executory because the accused had commenced serving it, rendering the judgment unappealable.
Ratio Decidendi
On the issue of appellate jurisdiction after commencement of sentence: The Supreme Court affirmed the trial court's denial of the motion to withdraw the guilty plea and the subsequent appeal. It unequivocally stated that a judgment in a criminal case becomes final under Section 7 of Rule 116 of the Rules of Court when the sentence has been partially or totally satisfied or served. This rule is a restatement of established jurisprudence. Once a judgment becomes final and executory, it is no longer appealable. The appellate court is divested of jurisdiction to review, reverse, or modify such a judgment. Any perceived error in the imposition of the penalty can only be corrected through executive clemency, not through an appeal. The fact that the accused had already begun serving his sentence was determinative of the finality of the judgment. Therefore, the trial court correctly ruled that it had lost jurisdiction to modify its earlier decision. The appeal, consequently, could not be entertained by the Supreme Court. On the issue of the trial court's denial of the motion to withdraw the plea: The trial court's denial was proper because the condition for the finality of the judgment, as stipulated in Section 7 of Rule 116, had been met. The accused had commenced serving his sentence, which made the judgment final and unappealable. The trial court's authority to modify or set aside its judgment generally ceases upon the finality of the judgment. The accused's attempt to withdraw his guilty plea and present evidence came too late, as the legal consequence of commencing service of sentence was the finality of the judgment. The Supreme Court reiterated that a final and executory judgment cannot be appealed. Therefore, the trial court acted within its jurisdiction in denying the motion and the subsequent appeal.
Main Doctrine
A judgment in a criminal case becomes final when the sentence has been partially or totally satisfied or served, or when the defendant has expressly waived in writing his right to appeal. Once final, the appellate court has no jurisdiction to review, reverse, or modify it.