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

The case originates from the Regional Trial Court (RTC) of Negros Oriental, Branch 45 in Bais City, where in Criminal Case No. 397-B, a judgment promulgated on December 1, 1993, found accused Francisco Palacios and his co-accused guilty beyond reasonable doubt of murder.
The judgment imposed reclusion perpetua on each defendant and also ordered them to pay P200,000.00 and P25,000.00 as actual damages and for funeral expenses, respectively.

Accused-appellants William Casido and Franklin Alcorin, found guilty in the RTC decision, filed a supplemental notice of appeal on December 8, 1993, thereby challenging the RTC’s judgment.
The appellate court accepted the appeal on December 7, 1994, enabling further proceedings on the matter.

On June 30, 1995, counsel for the accused-appellants filed the Appellants’ Brief, followed by the Office of the Solicitor General filing a Brief for the Appellee on September 28, 1995, urging affirmance in toto of the trial court’s decision.
An urgent motion to withdraw appeal was received on January 11, 1996, filed by the accused-appellants without stating any reason for such request.
At the motion’s lower portion, a 1st Indorsement dated January 5, 1996, by Venancio J. Tesoro, Superintendent IV of the Bureau of Corrections, noted that the legal consequences of the motion were explained to the accused and that the filing was done of their own free will.

On March 22, 1996, a 1st Indorsement dated March 18, 1996, from Superintendent Tesoro informed the court that the accused-appellants had been released on Conditional Pardon on January 25, 1996.
Subsequent directives required the submission of certified copies of the Conditional Pardon and the release order.
On April 29, 1996, counsel for the accused-appellants filed comments on the urgent motion to withdraw appeal, offering no objection.
On June 10, 1996 (received on June 14, 1996), Superintendent Tesoro submitted certified copies of the separate conditional pardons granted to William Casido and Franklin Alcorin, each signed by the President on January 19, 1996, together with certificates of discharge showing their release on January 25, 1996.

The court noted previous decisions – People vs. Hinlo, People vs. Sepada, and People vs. Salle – which clearly declared that the grant of any pardon, full or conditional, during the pendency of an appeal was in violation of law.
It was emphasized that the issuance of conditional pardons on January 19, 1996, while the appeal was still pending, rendered the pardons void under the “conviction by final judgment” limitation of the Constitution.

Whether the issuance of conditional pardons to accused-appellants William Casido and Franklin Alcorin during the pendency of their appeal violates the constitutional mandate that a pardon may only be granted after a final judgment has been rendered.

Whether the accused-appellants’ urgent motion to withdraw their appeal should be granted in light of the fact that they were released on conditional pardon during an active appeal process.

Whether the actions of the officers of the Presidential Committee for the Grant of Bail, Release, and Pardon, who approved and recommended the pardon applications despite the ongoing appeal, constitute a violation of the established legal framework and judicial precedents.