Case Digest (G.R. No. 159222)
Facts:
- The case involves the People of the Philippines and Hon. Bricio Ygana, Presiding Judge of the RTC, Branch 153, Pasig City, as petitioners against Rafael Bitanga, the respondent.
- Traders Royal Bank (TRB) filed a complaint against Bitanga, leading to an estafa charge in Criminal Case No. 103677.
- Bitanga pleaded "not guilty" and was allowed to post bail.
- During the trial, three TRB employees testified that Bitanga deceived the bank into accepting three foreign checks, which were later returned due to "unlocated accounts."
- Bitanga and his counsel failed to appear when it was time for the defense to present its case.
- A warrant for Bitanga's arrest was issued, and he was deemed to have waived his right to present evidence.
- On February 29, 2000, the RTC convicted Bitanga in absentia, sentencing him to imprisonment and ordering him to indemnify TRB P742,884.00.
- On January 28, 2002, Bitanga filed a Petition for Annulment of Judgment with the Court of Appeals (CA), claiming extrinsic fraud by his counsel, Atty. Benjamin Razon.
- Bitanga asserted he only received the RTC decision on December 13, 2001.
- The CA granted Bitanga's petition on March 31, 2003, citing extrinsic fraud and remanding the case for further proceedings.
- The People opposed the petition and filed a motion for reconsideration, which the CA denied on July 18, 2003.
- The People elevated the matter to the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court granted the petition, annulling the CA's March 31, 2003 Decision and July 18, 2003 Resolution.
- The Court held that the remedy of annulment of judgment under Rule 47 is not applicable to criminal cases....(Unlock)
Ratio:
- The Supreme Court reasoned that Rule 47's annulment remedy is limited to civil actions and does not extend to criminal cases, as stated in the 2000 Revised Rules of Criminal Procedure.
- The Court emphasized that the actions attributed to Bitanga'...continue reading
Case Digest (G.R. No. 159222)
Facts:
The case involves the People of the Philippines and the Hon. Bricio Ygana, Presiding Judge of the Regional Trial Court (RTC), Branch 153, Pasig City, as petitioners against Rafael Bitanga, the respondent. The events leading to this case began with a complaint filed by Traders Royal Bank (TRB) against Bitanga, resulting in an information for estafa being lodged before the RTC, which was docketed as Criminal Case No. 103677. Bitanga pleaded "not guilty" and was allowed to post bail. During the trial, the prosecution presented testimonies from three TRB employees, detailing how Bitanga deceived the bank into accepting three foreign checks for deposit, which were later returned due to "unlocated accounts." However, when it was time for the defense to present its case, Bitanga and his counsel failed to appear. Consequently, upon the public prosecutor's motion, a warrant for Bitanga's arrest was issued, and his right to present evidence was deemed waived. On February 29, 2000, the RTC rendered a decision in absentia, convicting Bitanga of estafa and sentencing him to imprisonment and ordering him to indemnify TRB the amount of P742,884.00.
On January 28, 2002, Bitanga filed a Petition for Annulment of Judgment with the Court of Appeals (CA), claiming that extrinsic fraud had been committed against him by his counsel, Atty. Benjamin Razon. He asserted that he only received a copy of the RTC decision on December 13, 2...