Case Digest (G.R. No. L-60892)
Facts:
The case involves Manuel Atienza as the petitioner and the Court of Appeals as the respondent. The events leading to this case began with Criminal Case No. P-933, titled "People v. Manuel Atienza," which was tried in the Court of First Instance of Oriental Mindoro. On December 13, 1985, the court rendered a decision finding Atienza guilty of "direct assault with less serious physical injuries." The court sentenced him to imprisonment ranging from one year and eight months to four years, two months, and one day, along with an order to indemnify the offended party, who was the president of the association of barangay captains, the amount of P1,000.00. Following his conviction, Atienza appealed the decision but simultaneously applied for probation. The trial court, on October 25, 1979, declared the appeal withdrawn and referred the probation application to the Provincial Probation Officer for investigation. However, the record does not indicate whether a repo...
Case Digest (G.R. No. L-60892)
Facts:
Criminal Case and Conviction:
- Manuel Atienza was convicted by the Court of First Instance of Oriental Mindoro in Criminal Case No. P-933 for the complex crime of "direct assault with less serious physical injuries."
- He was sentenced to imprisonment ranging from 1 year and 8 months (minimum) to 4 years, 2 months, and 1 day (maximum), along with an indemnity of P1,000.00 to the offended party.
Application for Probation:
- While his appeal was pending, Atienza applied for probation.
- The trial court withdrew his appeal and referred the probation application to the Provincial Probation Officer for investigation and recommendation.
- However, the record does not indicate whether a report was submitted by the probation officer.
Denial of Probation:
- On July 10, 1980, the trial court denied Atienza's application for probation, stating that granting probation would "depreciate the seriousness of the offense."
- The court based its decision on the following:
- The offended party was the president of the association of barangay captains and was 60 years old, 22 years older than Atienza.
- Atienza "fought the case to its bitter end" and presented an "unreliable version" of the incident, which the court interpreted as a lack of remorse.
Appeal to Higher Courts:
- Atienza filed a motion for reconsideration, which was denied.
- He then filed a certiorari petition with the Court of Appeals, which also dismissed his case.
- Atienza elevated the matter to the Supreme Court.
Issue:
- Whether the trial court erred in denying Atienza's application for probation on the grounds that it would "depreciate the seriousness of the offense."
- Whether the trial court's conclusion that Atienza lacked remorse was justified.
- Whether Atienza, as a first-time offender, is entitled to the benefits of probation under the Probation Law (P.D. 968).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court ruled in favor of Atienza, holding that the trial court's denial of his probation application was unjustified. The Court reiterated the liberality of the Probation Law in favor of first-time offenders and directed the trial court to process Atienza's application for probation.