Case Digest (G.R. No. 103567) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the case People of the Philippines vs. Francisco Salle, Jr. y Gercilla @ "Ka Nonoy," Ricky Mengote y Cuntado @ "Ka Ricky/Ka Liza/Ka Jun," and Ten John Does (G.R. No. 103567, December 4, 1995), the Regional Trial Court (RTC), Branch 88, Quezon City, found accused-appellants Francisco Salle, Jr. and Ricky Mengote guilty beyond reasonable doubt as co-principals of the compound crime of murder and destructive arson. They were sentenced to suffer reclusion perpetua and jointly and severally pay an indemnity of P50,000.00 to the heirs of the victim. The appellants timely filed their notice of appeal, which was accepted by the Supreme Court on March 24, 1993. During the pendency of the appeal, both Salle and Mengote were granted conditional pardons by the President on December 9, 1993, resulting in their release from confinement (Salle was released on December 28, 1993). Salle subsequently filed a motion to withdraw his appeal, which was granted by the Supreme C
Case Digest (G.R. No. 103567) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Case
- The accused-appellants Francisco Salle, Jr. y Gercilla, Ricky Mengote y Cuntado, and ten John Does were found guilty beyond reasonable doubt by the Regional Trial Court (RTC) of Quezon City, Branch 88, for the compound crime of murder and destructive arson. They were each sentenced to reclusion perpetua and jointly and severally liable to pay P50,000.00 indemnity to the heirs of the victim.
- The accused-appellants timely filed Notices of Appeal to this Court. On 24 March 1993, the Supreme Court accepted the appeal.
- Conditional Pardons and Motions to Withdraw Appeal
- On 6 January 1994, appellant Francisco Salle, Jr. filed a motion to withdraw his appeal. His counsel, Atty. Ida May La’o of the Free Legal Assistance Group (FLAG), verified that Salle signed the motion without legal assistance, under the false impression that it was a mere bureaucratic formality necessary for his early release following the grant of a conditional pardon by the President on 9 December 1993. Salle was released from New Bilibid Prison (NBP) on 28 December 1993.
- On the same dates, appellant Ricky Mengote was also granted a conditional pardon and released from confinement, but he left for his province without consulting counsel and had not filed a motion to withdraw his appeal.
- On 23 March 1994, this Court granted Salle’s motion to withdraw appeal and closed the case against him. Mengote’s appeal remained pending.
- Submission of Relevant Documents and Government Comments
- On 3 June 1993, the Bureau of Corrections submitted certified copies of the conditional pardons and certificates of release of both Salle and Mengote, noting that release was conditioned upon acceptance of the pardon, but no proof of acceptance date was shown.
- The Office of the Solicitor General (OSG) commented that acceptance of the conditional pardon indicated implied admission of guilt and acceptance of sentence; hence, the appeals should be dismissed.
- The Court required memoranda from the OSG and accused-appellants’ counsel and explanation from the Presidential Committee for the Grant of Bail, Release or Pardon on why the conditional pardon was recommended during the pendency of appeal.
- The Presidential Committee explained a standing agreement with FLAG and other human rights groups to recommend conditional pardons for convicted persons with political objectives even if appeals were pending, expecting withdrawal of appeals by the lawyers—but Mengote’s prison records failed to show a pending appeal, precluding advice to withdraw appeal. The Committee claimed no intent to violate the Constitution, attributing the error to incomplete records.
- Arguments Presented
- The OSG maintained the conditional pardon granted to Mengote was unenforceable due to the non-finality of the judgment on appeal.
- FLAG argued Mengote’s acceptance of the conditional pardon amounted to abandonment of his appeal, rendering the conviction final. They relied on the Court’s prior decision in Monsanto vs. Factoran, Jr.
- Essential Legal Question
Issues:
- Whether a conditional pardon granted by the President during the pendency of a criminal appeal from a judgment of conviction by the trial court is enforceable under Philippine law.
- Whether the acceptance of a conditional pardon during the pendency of appeal operates as an abandonment or waiver of the appeal, thereby rendering the conviction final.
- Whether a motion to withdraw appeal is necessary before a conditional pardon may take effect, given the requirements under the Constitution.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)