Facts:

The case of Manuel V. Bala vs. The Hon. Judge Antonio M. Martinez involved the petition of Manuel V. Bala, the petitioner, against Judge Martinez, the People of the Philippines, and Paul Ayang-Ang, a probation officer from the Manila Probation Office No. 4. The controversy arose from an order issued on April 2, 1984, by the Court of First Instance (now Regional Trial Court, RTC) of Manila, Branch XX, which denied the petitioner's motion to dismiss a motion to revoke his probation. The petitioner was convicted on January 3, 1978, for falsifying a public document, specifically by substituting the photo in a United States passport belonging to Maria Eloisa Criss Diaz with one belonging to Florencia Notarte. He was sentenced to an indeterminate prison term and a fine. After serving a part of his sentence, Bala was granted probation on August 11, 1982. However, he requested to change his residential address during the probation period, which was initially approved by his supervis

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Facts:

Background of the Case

• The petitioner, Manuel V. Bala, was indicted for removing and substituting the picture of Maria Eloisa Criss Diazen on her U.S. passport with that of Florencia Notarte, effectively falsifying an official document.
• On January 3, 1978, in Criminal Case No. 24443, the trial court found him guilty beyond reasonable doubt under Article 172 of the Revised Penal Code and sentenced him to an indeterminate term of prision correccional, a fine of P1,800.00 (with subsidiary imprisonment in case of insolvency), and the payment of costs.
• The petitioner’s appeal was filed and affirmed in toto by the Court of Appeals on April 9, 1980.

Grant of Probation

• After remand for the execution of judgment, the petitioner applied for and was granted probation by an order dated August 11, 1982.
• The probation was set for a period of one (1) year and was subject to several conditions, including residing at a specified address, gainful employment, and full cooperation with the supervisory rehabilitation program.
• Despite the probation period being scheduled to expire on August 10, 1983, no final order of discharge was issued because the probation officer had not yet submitted his final report on the petitioner’s conduct.

Alleged Violation and Revocation Proceedings

• On September 23, 1982, the petitioner requested to transfer his residence from BF Homes to Phil-Am Life Subdivision, Las Piñas, a request verbally granted by the probation officer.
• On December 8, 1983, the People, through Assistant City Fiscal Jose D. Cajucom, filed a motion to revoke the probation, alleging that the petitioner had violated the conditions of his probation.
• The petitioner opposed the motion on January 4, 1984, arguing that his probation period had already terminated on August 10, 1983, and that the change of residence automatically transferred jurisdiction to another court pursuant to Section 13, P.D. No. 968.

Subsequent Developments

• On January 6, 1984, the probation officer filed a motion to terminate the probation, which was subsequently modified on January 30, 1984, with a supplemental report recommending revocation in light of new facts and evidence.
• The petitioner filed a motion to dismiss and/or strike out the motion to revoke probation, questioning both the timeliness of revocation (since the probation period had allegedly expired) and jurisdiction issues arising from his change of residence.
• The respondent judge, however, denied the motion to dismiss for lack of merit, thus allowing the revocation proceedings to continue without resolving the evidentiary matter.

Additional Offenses and Final Circumstances

• Subsequent to the probation grant and before its final discharge, the petitioner was convicted on April 30, 1984, along with co-accused, for separate falsification offenses involving U.S. passports in multiple criminal cases (Nos. 29100–29107).
• The conviction led to additional prison sentences, fines, and further conditions. The petitioner’s failure to appear for judgment execution resulted in an order of arrest on July 10, 1989; however, he absconded after a warrant for arrest was issued on July 12, 1989.
• These actions established further violations of the terms of the probation, contributing to the cumulative basis for the petition’s revocation.

Issue:

Validity of Revocation Despite Probation Period Expiration

• Whether the mere expiry of the probation period (August 10, 1983) automatically terminates probation, thereby precluding further revocation proceedings.
• Whether the absence of a final discharge order (pending the probation officer’s report) implies that the probation still subsists and may hence be revoked for cause.

Jurisdiction and Venue Concerns Relating to Change of Residence

• Whether the petitioner’s transfer of residence from BF Homes to Phil-Am Life Subdivision, Las Piñas, automatically transfers jurisdiction over his probation case from the Regional Trial Court (RTC) of Manila to the RTC of Makati.
• Whether the verbal permission granted by the probation officer for the residence change is sufficient, in light of statutory requirements for written approval by the court, as mandated under Section 10 of P.D. No. 968 and the petitioner’s probation order.

Sufficiency and Impact of Probation Officer’s Report and Compliance with Conditions

• Whether the failure of the probation officer to submit his final report on the petitioner’s conduct justifies the continuation and subsequent revocation of probation.
• Whether the petitioner’s non-compliance with the stipulated conditions of probation (such as maintaining residence at the designated address and cooperating with the supervisory program) invalidates the probation and warrants its revocation.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)