Case Digest (G.R. No. 132601)
Facts:
Echegaray v. Secretary of Justice, G.R. No. 132601, January 19, 1999, Supreme Court En Banc, Puno, J., writing for the Court. Petitioner is Leo Echegaray (convict); respondents are the Secretary of Justice, et al. The resolution here concerns public respondents’ Urgent Motion for Reconsideration of this Court’s Resolution of January 4, 1999, which had issued a Temporary Restraining Order (TRO) temporarily restraining petitioner’s execution; the public respondents also filed a Supplemental Motion.The underlying procedural backdrop involves two related Supreme Court matters. In G.R. No. 117472 this Court conducted an automatic review of petitioner’s conviction and imposed the death penalty. Separately, in G.R. No. 132601 petitioner assailed the constitutionality of Republic Act No. 8177 (the Lethal Injection Law) and its implementing rules and regulations; the Court rendered a decision filed October 12, 1998, whose Entry of Judgment recited that on November 6, 1998 the decision became final and executory. The Entry of Judgment stated, inter alia, that R.A. 8177 was not declared unconstitutional but that Sections 17 and 19 of the Rules and Regulations implementing R.A. 8177 were invalid and that respondents were enjoined from enforcing R.A. 8177 until those sections were amended.
After entry of judgment the Secretary of Justice filed an October 21, 1998 Compliance and on October 28, 1998 manifested publication of amended rules and regulations. Separately, the Secretary and petitioner’s counsel sought from the trial court disclosure of the warrant of execution and the execution date; this Court granted relief in a December 15, 1998 Resolution compelling disclosure. On December 28, 1998 petitioner filed a Very Urgent Motion for Issuance of TRO (late night) alleging that his execution had been set for January 4, 1999 and asserting that there were credible moves in the newly constituted 11th Congress to repeal or review the death penalty law. Chief Justice Davide called a Special Session on January 4, 1999; the Court issued a TRO on that date temporarily restraining execution until June 15, 1999 (or sooner if it became certain no repeal/modification would occur).
Public respondents moved for reconsideration, arguing the Court had lost jurisdiction once its decision became final and that the TRO encroached on executive and legislative spheres; they pointed to supervening events (the President’s public statement to veto repeal, House Resolution No. 629 / House Resolution No. 25 opposing repeal, and limited Senate signatures) as demon...(Pro-only)
Issues:
- After a decision has become final and executory, does the Supreme Court retain jurisdiction to control, supervise or temporarily restrain the execution of that decision?
- Does issuance of a court-ordered temporary restraining order suspending execution usurp the President’s constitutional power to grant reprieves, commutations and pardons?
- Were the factual and prudential grounds invoked by petitioner (possibility of congressional repeal/amendment of the death penalty law) sufficient to justify the TRO and, in light...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)