Title
Andal vs. People
Case
G.R. No. 138268-69
Decision Date
May 26, 1999
Convicted of rape with homicide, petitioners sought habeas corpus, alleging mistrial and jurisdictional issues; Supreme Court upheld conviction and death penalty, denying petition.
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Case Digest (G.R. No. 138268-69)

Facts:

  1. Conviction and Execution: Petitioners Jury Andal, Ricardo Andal, and Edwin Mendoza were convicted of rape with homicide in Criminal Case Nos. 148-94 and 149-94 by the Regional Trial Court (RTC) of Batangas, Branch 05, Lemery. The conviction was affirmed by the Supreme Court in a decision en banc on September 25, 1997, and a resolution on February 17, 1998. They were scheduled for execution on June 16, 17, and 18, 1999.

  2. Petition for Habeas Corpus: The petitioners filed a petition for a writ of habeas corpus, claiming mistrial and arguing that the RTC decision was void. They sought a temporary restraining order or preliminary injunction to stay their execution.

  3. Alleged Violation of Constitutional Rights: The petitioners argued that the trial court was "ousted" of jurisdiction because the pre-trial identification of the accused was conducted without the assistance of counsel and without a valid waiver of their rights. They cited the case of Olaguer v. Military Commission No. 34 to support their claim.

  4. Evidence and Trial Proceedings: The prosecution's principal witness, Olimpio Corales, identified the accused. The defense failed to present Rufino Andal as a witness. The petitioners proposed DNA testing to compare semen samples with those taken from the victim, but the Court deemed this unnecessary.

  5. Death Penalty: The trial court imposed the death penalty, which was affirmed by the Supreme Court, as prescribed by Republic Act No. 7659 for rape with homicide.

Issue:

  1. Whether the writ of habeas corpus is the appropriate remedy to challenge the petitioners' conviction and impending execution.
  2. Whether the trial court was ousted of jurisdiction due to the alleged violation of the petitioners' constitutional rights during the pre-trial identification process.
  3. Whether the petitioners were deprived of due process and a fair trial.
  4. Whether the imposition of the death penalty was valid under the circumstances.

Ruling:

The Supreme Court denied the petition for habeas corpus and upheld the validity of the trial court's judgment, as affirmed by the Court. The Court ruled that:

  1. The writ of habeas corpus is not the appropriate remedy in this case, as the petitioners' claims do not demonstrate a violation of their constitutional rights or a deprivation of due process.
  2. The trial court had jurisdiction to try the case, and any alleged illegality during the arrest was cured when the petitioners voluntarily submitted to the court's jurisdiction by entering their plea.
  3. The evidence presented during the trial was sufficient to support the conviction, and the absence of Rufino Andal's testimony did not render the judgment invalid.
  4. The death penalty was correctly imposed under Republic Act No. 7659 for the crime of rape with homicide.

Ratio:

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