G.R. No. 116512 - People vs. Casido

The case involves the People of the Philippines versus accused-appellants William O. Casido and Franklin A. Alcorin.
Both accused were granted conditional pardons by the Presidential Committee for the Grant of Bail, Release or Pardon.
The conditional pardon was extended on January 19, 1996, during the pendency of their appeal, thereby raising constitutional concerns.

Prior to their release, the accused-appellants filed an urgent motion to withdraw their appeal, which was submitted to the Supreme Court on January 11, 1996.
Despite the filing of the motion, the pardon was executed by the Bureau of Corrections, leading to their release on January 25, 1996.
The Supreme Court, in its Resolution dated July 30, 1996, declared the conditional pardon void for having been granted before the final judgment.

The Court ordered the Bureau of Corrections, with the support of the Philippine National Police, to effect the re-arrest and reconfinement of the accused-appellants within sixty (60) days.
Further proceedings on the appeal were suspended pending the re-arrest of Casido and Alcorin.
The Court also mandated that the officers of the Presidential Committee show cause why they should not be held in contempt of court for proceeding with the pardon application without ensuring the withdrawal of the appeal by the accused or their legal representatives.

The Committee was originally constituted by the President as part of confidence building measures, with the task of recommending the grant of bail, release, or pardon for persons involved in crimes against national security and related offenses.
Its membership included high-ranking officials from the Department of Justice, National Defense, and the Interior and Local Government; later, the composition was expanded to include representatives from the Commission on Human Rights and other agencies.
Accompanying the Committee was a Secretariat composed of representatives from several government agencies such as the Office of the Chief State Prosecutor, the Bureau of Corrections, the Philippine National Police Legal Service, and others.

The Secretariat was charged with processing applications for pardon and, in connection with this task, coordinated with non-government organizations (NGOs) like the Task Force Detainees of the Philippines (TFDP), the Free Legal Assistance Group (FLAG), KAPATID, and PAHRA.
An understanding was reached that, as a condition for acting on an application for pardon, the applicants’ lawyers (generally from NGOs) would simultaneously file motions to withdraw the accused’s appeal.
The Secretariat, relying on the verbal undertakings of these NGOs, forwarded the applications for conditional pardon without obtaining written confirmation of the withdrawal of appeals, a critical lapse that later became central to the case.

A letter from the National Amnesty Commission (NAC) disclosed that amnesty was granted to the accused-appellants on February 22, 1996, under Proclamation No. 347.
The NAC’s decision was based on a review of the accused’s conviction for crimes committed in pursuit of political objectives, thereby extinguishing their criminal liability and restoring their civil or political rights.
While the conditional pardon was later ruled void, the release of the accused was ultimately justified on the ground of the validly granted amnesty.

Whether the conditional pardon was valid when granted while the appeal was still pending, in light of Section 19, Article VII of the Constitution.
Whether the failure of the Presidential Committee and its Secretariat to secure written confirmation of the withdrawal of appeals rendered the pardon procedurally and substantively defective.

Whether the subsequent grant of amnesty by the National Amnesty Commission could retroactively justify the accused-appellants’ release despite the void conditional pardon.
How the distinct characteristics and legal effects of pardon versus amnesty affect the validity of the release.

To what extent the Secretariat and the Presidential Committee should be held administratively accountable for not observing the requisite procedures.
Whether their actions, based on verbal assurances from NGOs, could be excused under the guise of acting in good faith as part of a confidence building measure.