Case Digest (G.R. No. 114282)
Facts:
The case involves Aceyork Aguilar (petitioner) and Ma. Lourdes Salvador (co-accused), who were charged with Estafa in an Information filed before the Regional Trial Court of Makati. During the arraignment, both entered a plea of not guilty. The trial court subsequently convicted them on July 19, 1991, sentencing them to an indeterminate penalty of 17 years and 4 months of reclusion temporal as minimum to 20 years of reclusion temporal as maximum, along with an order to indemnify the offended party in the amount of two hundred fifty thousand pesos (P250,000.00) without subsidiary imprisonment in case of insolvency. Following the conviction, Aguilar, through his former counsel Atty. Edgardo Arandia, filed a timely appeal to the Intermediate Appellate Court (now known as the Court of Appeals). However, Atty. Arandia failed to file the appellant's brief by the due date and did not communicate with Aguilar regarding this failure, nor did he withdraw his representation. After s...
Case Digest (G.R. No. 114282)
Facts:
Parties Involved:
Petitioner: Aceyork Aguilar (Ace Vergel)
Respondents: Court of Appeals and the People of the Philippines
Charges and Conviction:
Aceyork Aguilar and Ma. Lourdes Salvador were charged with Estafa before the Regional Trial Court (RTC) of Makati. Both pleaded not guilty. On July 19, 1991, the RTC convicted them and sentenced them to an indeterminate penalty of 17 years and 4 months to 20 years of reclusion temporal, plus indemnification of P250,000.
Appeal Process:
Petitioner timely appealed to the Court of Appeals (then the Intermediate Appellate Court) through his former counsel, Atty. Edgardo Arandia. However, Atty. Arandia failed to file the appellant's brief on time and did not communicate with petitioner or withdraw as counsel.
New Counsel and Motion for Extension:
On January 22, 1993, Atty. Marcelino Arias entered his appearance as petitioner’s new counsel and requested a 45-day extension to file the appellant’s brief. The Court of Appeals denied the motion on March 15, 1993, for being filed out of time.
Dismissal of Appeal:
Petitioner filed motions to reconsider the denial and admit the appellant’s brief on April 6, 1993. However, the Court of Appeals dismissed the appeal on July 30, 1993, citing the late filing of the brief.
Petitioner’s Arguments:
Petitioner argued that he was an ordinary layman unaware of legal procedures and unfairly abandoned by his former counsel. He also highlighted that his co-accused’s appeal brief was admitted "in the interest of substantial justice," and he sought equal treatment.
Issue:
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Ruling:
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Ratio:
Right to Appeal: Appeal is an essential part of the judicial system, and courts should exercise caution to avoid depriving a party of this right. Technicalities should not override the demands of substantial justice.
Equal Protection: Petitioner’s co-accused was granted an extension to file her brief, and her appeal was admitted in the interest of justice. There was no valid reason to treat petitioner differently, as both cases rested on the same facts.
Negligence of Counsel: Petitioner should not bear the consequences of his former counsel’s negligence, especially when his liberty is at stake. Courts have the power to relax procedural rules to prevent a miscarriage of justice.
Efforts to Comply: Petitioner’s new counsel filed the appellant’s brief on April 6, 1993, demonstrating earnest efforts to comply with the court’s requirements. This should be considered as indicative of a lack of intention to cause delay.
Conclusion: The Court emphasized that litigation should be resolved on the merits rather than on technicalities, especially in criminal cases where liberty is at stake.