Title
Chavez vs. Court of Appeals
Case
G.R. No. L-29169
Decision Date
Aug 19, 1968
Roger Chavez, convicted of qualified theft, claimed his right against self-incrimination was violated when compelled to testify against himself. The Supreme Court ruled in his favor, voiding his conviction and ordering his release.

Case Digest (G.R. No. L-29169)
Expanded Legal Reasoning Model

Facts:

  • Background of the Alleged Crime
    • On November 14, 1962, in Quezon City, nine persons (including petitioner Roger Chavez, Ricardo Sumilang alias “Romeo Vasquez,” Edgardo Pascual alias “Ging,” Pedro Rebullo alias “Pita,” Luis Asistio alias “Baby,” Lorenzo Meneses alias “Lory,” and three unidentified “Does”) were charged by third amended information with qualified theft of a Thunderbird car valued at ₱22,200 belonging to Dy Sun Hiok y Lim and sold by Johnson Lee.
    • The prosecution alleged a conspiracy: Chavez acted as agent, introduced Sumilang to Lee, procured signing of a deed of sale under pretense, then absconded with the car. The vehicle was later recovered and repainted; proceeds were shared among conspirators, and title transfers were effected in Sumilang’s and Asistio’s names.
  • Trial, Conviction and Appeal
    • Upon arraignment before Branch IX, CFI Rizal (Quezon City) on July 23, 1963, all named accused pleaded not guilty. The trial opened with the prosecution calling Chavez—one of the accused—as its first witness.
    • Defense counsel objected that calling Chavez violated his constitutional right against self-incrimination; the trial judge overruled, granted a brief recess but insisted Chavez must testify. Chavez then recounted the plan and execution, identifying co-accused involvement.
    • On February 1, 1965, the trial court acquitted all co-accused except Chavez, finding his compelled testimony “establishes his guilt beyond reasonable doubt” and branding him a “self-confessed culprit.” He was sentenced to an indeterminate term of 10 years, 1 day to 14 years, 8 months, 1 day; indemnity of ₱21,000; accessory penalties; costs; and ordered to return or pay balance of ₱21,500 to Asistio.
    • Chavez appealed to the Court of Appeals. After his counsel failed to file a brief, the CA dismissed the appeal on May 14, 1968 (affirmed June 21, 1968), ordered remand for execution, and issuance of a warrant for Chavez’s transfer to Muntinlupa Prison.

Issues:

  • Whether the trial court violated Chavez’s constitutional privilege against self-incrimination by compelling him to testify as a prosecution witness.
  • Whether the compelled testimony deprived the trial court of jurisdiction, rendering the conviction void.
  • Whether habeas corpus is the appropriate remedy to set aside the conviction in Criminal Case Q-5311.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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