Facts:
On June 19, 1987,
Rodolfo Basilonia,
Leodegario Catalan, and
John Basilonia were convicted in Criminal Case Nos. 1773, 1774, and 1775 by the Regional Trial Court in Roxas City, with the offenses arising from incidents dated September 15, 1983. The June 19, 1987 Decision found Rodolfo Basilonia, Leodegario Catalan, and John “Jojo” Basilonia guilty beyond reasonable doubt as principals in Criminal Case No. 1773 for the murder of
Atty. Isagani Roblete, imposing an indeterminate sentence of
twelve years, one month and one day of reclusion temporal as minimum to
twenty years, one day of reclusion temporal as maximum, and ordering them, jointly and severally, to indemnify the heirs of the victim with
P30,000.00 for death and
P32,100.00 for funeral and wake-related expenses, plus costs of suit. In Criminal Case No. 1775 for frustrated murder, John “Jojo” Basilonia was found guilty beyond reasonable doubt for frustrated homicide and was sentenced to an indeterminate penalty of
two years, four months and one day of prision correccional as minimum to
six years and one day of prision mayor as maximum, plus costs. The Decision acquitted other accused in those cases, and acquitted all accused in Criminal Case No. 1774 for illegal possession of firearm due to insufficiency of evidence. Petitioners filed a Notice of Appeal on July 30, 1987, which the trial court granted. On January 23, 1989, the Court of Appeals dismissed the appeal for failure to file the required brief despite extensions of time, and the Resolution was entered in the Book of Entries of Judgment on September 18, 1989; the records were remanded to the trial court on October 4, 1989. Nearly twenty years later, on May 11, 2009,
Dixon C. Roblete, claiming to be the son of the deceased victim, filed a
Motion for Execution of Judgment in the trial court, alleging that despite attempts to request execution through the City Prosecutor, the judgment had not been enforced. The Assistant City Prosecutor filed an omnibus motion for execution and issuance of a warrant of arrest on May 22, 2009. Petitioners responded and also filed a Petition for Relief of Judgment with the Court of Appeals on July 24, 2009, and filed a supplemental opposition in the trial court on September 1, 2009. The trial court granted the motion for execution on December 3, 2009 and ordered petitioners’ bondsmen to surrender them within ten days from notice; the denial of petitioners’ motion for reconsideration followed on January 4, 2010, and after petitioners failed to appear, bail was forfeited on January 25, 2010 and a writ of execution issued the same day. Petitioners then sought certiorari, questioning whether the trial court still had jurisdiction to grant execution almost twenty years after the judgment’s entry, particularly invoking
Section 6, Rule 39 of the Rules.
Issues:
Whether the trial court still had jurisdiction to grant
execution of the criminal judgment through a motion filed almost twenty years after the judgment became final, considering
Section 6, Rule 39 of the Rules and the related rules on
prescription and
extinction of civil liability.
Ruling:
Ratio:
Doctrine: