Facts:

The case at bar, Fidel Abriol v. Vicente Homeres, involves a petition for habeas corpus initiated by Fidel Abriol, the petitioner and appellant, who was sentenced to imprisonment for illegal possession of firearms and ammunition. This case originated from Criminal Case No. 1472, heard in the Court of First Instance of Leyte, where Abriol, alongside six others, was charged. After the prosecution presented its evidence, Abriol's counsel moved for dismissal based on the insufficient evidence; however, the court, presided over by Judge S. C. Moscoso, denied the motion. Subsequently, Abriol's counsel attempted to present evidence for the defense, which was met with opposition from the provincial fiscal, arguing that procedural laws precluded this following the dismissal motion's denial. The court sided with the fiscal, prohibiting the defense from presenting evidence and leading to the conviction of all accused parties. Abriol was sentenced to seven years of imprisonment

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Facts:

Background and Proceedings of the Case

• Fidel Abriol, petitioner and appellant, was one of seven accused in criminal case No. 1472 for illegal possession of firearms and ammunition.
• The prosecution presented its evidence first, and after its completion, the defense moved to dismiss the case on the ground of insufficiency of the evidence.

Trial Court Decision and Denial of Defense Evidence

• The trial court, presided by Judge S. C. Moscoso, denied the defense’s motion for dismissal despite the defense’s claim that the prosecution’s evidence was inadequate.
• Subsequent to the denial of the dismissal motion, the defense offered to present evidence on behalf of the accused, but both the trial court and the provincial fiscal opposed and disallowed the presentation of such evidence.
• As a result, the accused was convicted solely on the evidence presented by the prosecution.

Post-Trial Developments

• Fidel Abriol, together with his co-accused, appealed the conviction to the Court of Appeals.
• The Court of Appeals dismissed the appeal on its own motion for failure of the appellants to file a brief within the extended time allowed.
• Subsequently, while in custody, petitioner filed a petition for habeas corpus claiming that his sentence was null and void because his constitutional right to be heard (to present evidence) was violated.
• The trial court, later presiding over the habeas corpus petition (Judge Rodolfo Baltasar), denied the petition on the ground that the judgment of conviction had become final, thereby rendering the court devoid of jurisdiction to alter the decision.

Constitutional and Precedential Context

• The petitioner relied on the constitutional guarantee in Article III, Section 1(17) of the Bill of Rights, which mandates that in all criminal prosecutions the accused shall be given an opportunity to be heard, either personally or by counsel.
• The trial court’s approach was based on the procedural practice and cited precedent (United States vs. De la Cruz, 28 Phil. 279) which purportedly supported barring the accused from presenting evidence once a motion for dismissal had been filed and denied.
• The majority opinion noted a misapplication of precedent because no law permits the complete denial of the defense’s right to present evidence after the prosecution has rested, thus infringing on due process.

Issue:

Whether the trial court’s refusal to allow the petitioner to present evidence after the denial of his motion for dismissal violated his constitutional right to be heard in his defense.

• Did the court err by relying on a procedural practice inconsistent with the constitutional guarantee of due process?
• To what extent was the accused’s right to present evidence derivatively ensnared within his motion to dismiss, and was any waiver intended or implied?

The Applicability of Habeas Corpus as a Remedy

• Can habeas corpus be invoked as a substitute for the appellate process when a procedural error concerning the right to present evidence is alleged?
• Is the error in denying the opportunity to offer defense evidence jurisdictional in nature so as to justify the collateral attack through habeas corpus?

The Remedial Nature of the Decision

• Whether the error committed by the trial court should result in the nullification of the sentence entered against the petitioner.
• Should the case be remanded for a new trial at the point where the constitutional right to be heard was infringement or be treated as a final sentencing decision despite the error?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)