Case Digest (G.R. No. 183152-54)
Facts:
- Petitioners: Reynaldo H. Jaylo, William Valenzona, Antonio G. Habalo - officers of the Philippine National Police Western Police District detailed with the National Bureau of Investigation (NBI).
- 1990 Incident: In June, the US Drug Enforcement Agency (US DEA) informed the NBI about a heroin sale in the Philippines.
- Operation Lead: Jaylo was assigned to lead a buy-bust operation with US DEA undercover agent Philip Needham.
- Negotiation: From July 3 to 8, Needham negotiated with Estella Arrastia, Franco Calanog, and Rolando De Guzman for the purchase of 10 kilos of heroin.
- Set Exchange: The exchange was scheduled for July 10 at the Magallanes Commercial Center parking lot.
- Confrontation: A confrontation ensued during the operation, resulting in the deaths of De Guzman, Calanog, and Avelino Manguera.
- Conflicting Accounts: The prosecution and defense presented differing accounts of the incident.
- Elma Committee: Created by President Corazon Aquino, recommended the prosecution of Jaylo, Castro, Valenzona, and Habalo for the killings.
- Charges: They were charged with conspiracy in the murder of De Guzman, Calanog, and Manguera.
- Sandiganbayan Verdict: They were found guilty of homicide and sentenced to imprisonment and perpetual disqualification from public office.
- Non-Appearance: The petitioners did not attend the promulgation of the judgment, leading to the finality of their conviction and the loss of their remedies against the judgment.
Issue:
- (Unlock)
Ruling:
- Conspiracy and Fulfillment of Duty: The Sandiganbayan did not err in its findings regarding the absence of conspiracy and the justifying circumstance of fulfillment of duty.
- Testimonies and Evidence: The Sandiganbayan did not err in its assessment of the testimonies and evidence presented.
- Section 6,...(Unlock)
Ratio:
- Supreme Court's Decision: The Supreme Court upheld the Sandiganbayan's decision, noting that the petitioners' failure to appear at the promulgation of the judgment without justifiable cause resulted in the loss of their remedies against the judgment.
- Section 6, Rule 120: Mandates that an accused who fails to appear at the promulgation of a judgment of conviction without justifiable cause loses the remedies available against the judgment.
- Statutory Grant: The right to file a motion for reconsideration is a statutory grant and must be exercised ...continue reading
Case Digest (G.R. No. 183152-54)
Facts:
The case involves petitioners Reynaldo H. Jaylo, William Valenzona, and Antonio G. Habalo, who were officers of the Philippine National Police Western Police District detailed with the National Bureau of Investigation (NBI). In June 1990, the United States Drug Enforcement Agency (US DEA) informed the NBI about a heroin sale in the Philippines. Jaylo was assigned to lead a buy-bust operation with US DEA undercover agent Philip Needham. From July 3 to 8, 1990, Needham negotiated with Estella Arrastia, Franco Calanog, and Rolando De Guzman for the purchase of 10 kilos of heroin. The exchange was set for July 10, 1990, at the Magallanes Commercial Center parking lot. During the operation, a confrontation ensued, resulting in the deaths of De Guzman, Calanog, and Avelino Manguera. The prosecution and defense presented conflicting accounts of the incident. The Elma Committee, created by President Corazon Aquino, recommended the prosecution of Jaylo, Castro, Valenzona, and Habalo for the killings. They were charged with conspiracy in the murder of De Guzman, Calanog, and Manguera. The Sandiganbayan found them guilty of homicide and sentenced them to imprisonment and perpetual disqualification from public office. The petitioners failed to appear at the promulgation of the judgment, ...