G.R. No. 138268-69 - Andal vs. People

Petitioners – Jury Andal, Ricardo Andal, and Edwin Mendoza – were convicted of rape with homicide in Criminal Cases No. 148-94 and 149-94 before the Regional Trial Court (RTC), Batangas, Branch 05, Lemery.
Their convictions were affirmed by the Supreme Court in an en banc decision dated September 25, 1997, and subsequently by a resolution on February 17, 1998.
The petitioners were scheduled for execution on June 16, 17, and 18, 1999.

The petition was filed through a writ of habeas corpus, contesting that the RTC was “ousted” of jurisdiction due to a pre-trial identification conducted without the assistance of counsel and without a valid waiver from the accused.
Petitioners argued that such procedural irregularity amounted to a deprivation of their constitutional rights, thereby warranting a temporary restraining order (TRO) or preliminary injunction to stay their execution.
This claim was anchored on the assertion that a violation of a constitutional right, as discussed in related jurisprudence (e.g., the separate opinion in Olaguer v. Military Commission No. 34), should render the court’s judgment void under the doctrine of exhaustion of constitutional safeguards.

The Supreme Court observed that there was no substantial evidence of mistrial or deprivation of constitutional rights during the proceedings.
The evidence on record, which included physical evidence (such as the earring recovered from Jury Andal) and the lawful conduct of the search incident to arrest, supported the conviction.
The failure to present additional witnesses, such as Rufino Andal, by the defense did not impact the sufficiency or legality of the trial proceedings.

The petition was essentially viewed as an attempt to re-litigate a final and affirmed decision, rather than a genuine application for a writ of habeas corpus to redress illegal detention or deprivation of liberty.
The case invokes the power of judicial review to correct grave abuses of discretion; however, this review is limited to situations where there is clear evidence that the constitutional rights of the accused were violated.

Whether the pre-trial identification conducted without counsel’s assistance (and without a valid waiver) amounted to a deprivation of the petitioners’ constitutional rights.
Whether such a deprivation would be sufficient to oust the trial court of its jurisdiction, thus rendering the judgment void.

Whether the extraordinary remedy of habeas corpus is applicable when the alleged constitutional violation does not result in the deprivation of liberty.
Whether the petition constitutes a permissible inquiry into the legality of the detention or is merely an attempt to reconsider a final judgment.

Whether the evidence presented at trial, including statutory evidence and testimony of key witnesses, was adequate to support the imposition of the death penalty.
The necessity (or lack thereof) of DNA testing when the accused were properly identified by the prosecution’s principal witness.

Whether the imposition of the death penalty was legally and constitutionally appropriate given the evidence and subsequent judicial rulings.