Facts:

The case at hand is "The People of the Philippine Islands vs. Filemon Fresco," decided by the Supreme Court of the Philippines on September 30, 1936, under G.R. No. 44934. The case originated in the Court of First Instance of Manila, where an information was filed against the defendant, Filemon Fresco, for the crime of rape accompanied by serious physical injuries. Upon his arraignment, Fresco pleaded not guilty to the charges. Following a trial, the lower court convicted him of the crime and sentenced him to imprisonment for a period ranging from fourteen years, eight months, and one day to seventeen years, four months, and one day of reclusion temporal. Additionally, he was ordered to indemnify the victim in the amount of P100, without the possibility of subsidiary imprisonment in case of insolvency, and to pay the costs of the proceedings. Fresco appealed the judgment, and due to his inability to secure legal representation, he was assigned an attorney de oficio....

Facts:

1. Case Background:

   • The case involves Filemon Fresco, who was charged with the crime of rape with serious physical injuries in the Court of First Instance of Manila.
   • Upon arraignment, Fresco pleaded not guilty.
   • After trial, he was convicted and sentenced to imprisonment ranging from 14 years, 8 months, and 1 day to 17 years, 4 months, and 1 day of reclusion temporal. He was also ordered to indemnify the offended party with P100 and pay the costs.

2. Appeal and Legal Representation:

   • Fresco appealed the judgment but was unable to employ a lawyer. As a result, he was provided with an attorney de oficio (court-appointed counsel).
   • The attorney de oficio admitted Fresco's guilt in the brief filed but questioned the correctness of the penalty imposed by the lower court.

3. Appellant's Claim of Innocence:

   • While the appeal was pending, Fresco wrote a letter to one of the members of the court, claiming his innocence and disputing the findings of the lower court.
   • This created a conflict between Fresco and his court-appointed counsel regarding the issues to be raised on appeal.

4. Jurisdictional Issue:

   • The case initially involved only a question of law (the correctness of the penalty). However, Fresco's claim of innocence introduced a question of fact (his guilt or innocence).

Issue:

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Ruling:

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Ratio:

1. Conflict Between Client and Counsel:

   • When a client disagrees with their counsel on the issues to be raised on appeal, the court must ensure that the client's rights are protected. In this case, Fresco's claim of innocence necessitated a review of the factual evidence, even though his counsel had only raised a legal issue.

2. Jurisdiction Based on Questions of Law and Fact:

   • The Supreme Court has jurisdiction over cases involving only questions of law. However, when a case involves both questions of law and fact, it falls within the jurisdiction of the Court of Appeals.

3. Ends of Justice:

   • The court emphasized that the ends of justice require a review of the evidence to determine Fresco's guilt or innocence, especially in light of his claim of innocence.