Case Digest (G.R. No. 210972)
Facts:
The case involves Roger Allen Bigler as the petitioner and the People of the Philippines along with Linda Susan Patricia E. Barreto as the respondents. The events leading to this case began when Bigler was charged with libel in the Regional Trial Court (RTC) of Makati City, Branch 59, for allegedly defaming his former spouse, Barreto, through a letter sent to her lawyer. The letter purportedly contained various malicious and defamatory statements about her. Bigler pleaded "not guilty," and the trial proceeded. On November 21, 2003, Bigler's counsel filed a Withdrawal of Appearance, requesting that all legal notices be sent to Bigler's new address in Puerto Galera, Oriental Mindoro. Subsequently, on November 25, 2003, the RTC found Bigler guilty of libel and sentenced him to imprisonment for a period ranging from one year, eight months, and twenty-one days to two years, eleven months, and ten days, along with the costs of the suit. Bigler filed a motion for r...
Case Digest (G.R. No. 210972)
Facts:
Background of the Case
Petitioner Roger Allen Bigler was charged with the crime of Libel before the Regional Trial Court (RTC) of Makati City for allegedly defaming his former spouse, private respondent Linda Susan Patricia E. Barreto, through a letter sent to her lawyer. The letter contained malicious and defamatory imputations against her. Petitioner pleaded "not guilty," and the case proceeded to trial.
Withdrawal of Counsel and Promulgation of Judgment
On November 21, 2003, petitioner's counsel filed a Withdrawal of Appearance, requesting that all notices and legal processes be sent to petitioner's address or to his new counsel. On November 25, 2003, the RTC found petitioner guilty of Libel and sentenced him to imprisonment for one (1) year, eight (8) months, and twenty-one (21) days to two (2) years, eleven (11) months, and ten (10) days, plus costs of suit.
Motion for Reconsideration and Arrest
Petitioner filed a Motion for Reconsideration on February 9, 2004, which was denied on May 22, 2006. A Warrant of Arrest was issued on the same day, and petitioner was arrested on October 8, 2010.
Urgent Omnibus Motion and Notice of Appeal
Following his arrest, petitioner filed an Urgent Omnibus Motion on October 13, 2010, seeking to reopen the proceedings, allow him to file a Notice of Appeal, and recall the Warrant of Arrest. He claimed he never received notice of the RTC's Decision or the Order denying his Motion for Reconsideration. He also filed a Notice of Appeal on October 22, 2010.
RTC's Denial of Motion
The RTC denied petitioner's Urgent Omnibus Motion and Notice of Appeal on November 3, 2010, ruling that the Notice of Promulgation was sent to petitioner's address and received by his employee. The RTC also found that petitioner's Motion for Reconsideration was filed out of time, rendering the judgment final and executory.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Finality of Judgment
The Court emphasized the doctrine of finality of judgment, which renders a decision immutable and unalterable once it has become final. However, the Court has the discretion to relax this rule in exceptional cases, such as when the penalty imposed exceeds the legal maximum.Validity of Promulgation
The Court upheld the validity of the promulgation of the judgment, noting that petitioner was present during the promulgation and assisted by counsel. The Court also found that petitioner's Motion for Reconsideration was filed out of time, rendering the judgment final and executory.Modification of Penalty
While the judgment had become final, the Court modified the penalty imposed on petitioner because it exceeded the maximum allowed by law. This modification was made in the interest of substantial justice, consistent with previous cases where the Court corrected penalties that were outside the legal range.Jurisdiction Over Excess Penalty
The Court reiterated that a sentence imposing a penalty beyond the maximum authorized by law is void for excess of jurisdiction. Thus, the Court corrected the penalty to ensure it fell within the legal limits.