G.R. No. 183822 - Corpuz vs. Spouses Agustin

The petitioners—Francisco Evaristo, Pedro Cardeno, and Agustin Miano—were charged with murder for the killing of Pastor Muyot, along with six co-defendants who were later acquitted for insufficiency of evidence.
An amended information was filed in the Court of First Instance of Samar charging them with murder.

On March 29, 1958, the Court of First Instance of Samar rendered judgment (dated March 11, 1958) convicting the petitioners, sentencing them to reclusion perpetua with accessory penalties (such as indemnification of the victim’s heirs and payment of proportionate costs).
The judgment resulted in the petitioners being legally designated as defendants.

On the same day as the judgment (March 29, 1958), the petitioners filed a notice of appeal and served a copy on the Provincial Fiscal, thereby perfecting the appeal in accordance with Rule 118.
Subsequently, on April 10, 1958, the petitioners moved for a new trial on the grounds of newly discovered evidence.
On July 28, 1958, the petitioners sought leave to amend their original motion by attaching an amended motion for a new trial.

On August 7, 1958, the Court of First Instance declined to take cognizance of the petitioners’ amended motion for a new trial, ruling a lack of jurisdiction on the ground that the petitioners had already perfected their appeal.
The essential legal contention centered on whether the trial court retained jurisdiction to entertain the motion for a new trial once a notice of appeal had been duly filed and perfected.

Criminal appeals require the filing of a notice of appeal with the court that rendered the judgment and serving a copy upon the adverse party within fifteen days from the judgment’s rendition.
Within five days of the notice filing, the trial court must transmit the complete record and notice of appeal to the court of appellate jurisdiction.
Precedents (e.g., Director of Prisons vs. Teodoro, Sr.; People vs. Aranda) establish that the trial court loses jurisdiction to decide motions on the merits of the case, save for incidental orders for the protection of rights, once the appeal is perfected.

People vs. Bocar and People vs. Agasang were cited to discuss the timeliness and jurisdictional aspects of motions for a new trial, particularly in instances where an appeal is automatically reviewed by the Supreme Court because of the imposition of the death penalty.
The cases elaborate that even if a motion for a new trial is filed within the reglementary period, its consideration may be precluded by the perfection of the appeal, which transfers jurisdiction from the trial court to the appellate court.

Whether the trial court maintained jurisdiction to entertain the petitioners’ motion for a new trial after the filing and perfection of their notice of appeal.
Whether the filing of a notice of appeal effectively precluded the trial court from considering the subsequent motion for new trial.

Whether the rules and precedents set forth in cases such as People vs. Bocar, People vs. Agasang, Director of Prisons vs. Teodoro, Sr., and People vs. Aranda apply to situations where an appeal is perfected and impacts the trial court’s jurisdiction.
Whether the trial court’s decision to decline the motion for a new trial based on lack of jurisdiction was in consonance with the principles of appellate procedure.

Whether the petitioners’ actions in perfecting the appeal by filing the notice on March 29, 1958, and performing the requisite service constituted a complete and sufficient compliance with the rules, thereby terminating the trial court’s jurisdiction over new trial motions.
Whether any exceptions or doctrines exist under which the trial court could still consider a post-appeal motion for a new trial.