Case Digest (G.R. No. 240053)
Facts:
In People v. Sergio and Lacanilao (G.R. No. 240053, March 21, 2022), Mary Jane Veloso arrived at Adisucipto International Airport in Yogyakarta, Indonesia, carrying 2.6 kilograms of heroin and was arrested, tried, convicted of drug trafficking, and sentenced to death by firing squad under Indonesian law. She had been recruited by Maria Cristina P. Sergio and Julius L. Lacanilao through false promises of overseas employment and, upon her detention abroad, became the prosecution’s key witness against them for Qualified Trafficking in Persons under R.A. 9208, Illegal Recruitment under R.A. 8042, and Estafa under the Revised Penal Code. Believing Veloso’s testimony indispensable, Philippine prosecutors requested the Indonesian government to suspend her execution to permit her deposition by written interrogatories. The Regional Trial Court (Branch 88, Sto. Domingo, Nueva Ecija) granted this request under Rules 23 and 25 of the Revised Rules of Court, prescribing a detailed procedureCase Digest (G.R. No. 240053)
Facts:
- Arrest, Conviction, and Charges
- Mary Jane Veloso was arrested at Adisucipto International Airport, Yogyakarta, Indonesia, for carrying 2.6 kg of heroin.
- She was tried, convicted for drug trafficking, and sentenced to death by firing squad under Indonesian law.
- Maria Cristina Sergio and Julius L. Lacanilao allegedly induced Veloso to travel abroad on a false promise of work.
- In the Philippines, they were charged with Qualified Trafficking in Persons (RA 9208), Illegal Recruitment (RA 8042), and Estafa (RPC).
- Request for Testimony by Deposition
- Philippine prosecutors requested the Indonesian government to suspend Veloso’s execution to secure her testimony in the trafficking case.
- Indonesia agreed on conditions:
- Veloso must remain in Indonesian custody.
- Questions must be submitted in writing.
- No cameras or lawyers present during the deposition.
- RTC Branch 88 (Sto. Domingo, Nueva Ecija) granted leave to take Veloso’s testimony by deposition upon written interrogatories under Rules 23 and 25, prescribing:
- Periods for the accused’s comments and objections to proposed interrogatories.
- Conduct of the deposition in Yogyakarta before the trial judge and Philippine Consular officers.
- Transcription of verbatim answers by consular staff.
- Submission and ruling on cross-interrogatories and possible re-direct.
- Appellate Proceedings
- Sergio and Lacanilao petitioned the Court of Appeals by certiorari, which reversed the RTC, finding grave abuse of discretion.
- The People appealed to the Supreme Court.
- On October 9, 2019, the SC reversed the CA, reinstated and affirmed the RTC resolution with the modification that the deposition be taken before Philippine consular officials in Indonesia pursuant to the Rules of Court. The Decision became final on March 4, 2020.
- Urgent Omnibus Motion for Supplemental Instructions
- The OSG filed an Urgent Omnibus Motion (Dec. 4, 2020) seeking specific instructions to comply with new Indonesian conditions:
- Deposition to be conducted by the Indonesian Attorney General or appointee, with possible presence of PH consular officers and presiding judge.
- Deposition venue to be the prison facility in Wirogunan, Indonesia.
- The SC noted the motion without action, invoking the finality of its Decision and deferring technical foreign-relations details to the executive department.
Issues:
- Whether the Supreme Court may entertain and grant the OSG’s Urgent Omnibus Motion to amend its October 9, 2019 Decision.
- Whether the requested amendment falls within recognized exceptions to the finality of judgments (clerical error correction, nunc pro tunc entry, or void judgment).
- Which branch of government has the prerogative to negotiate and implement the technical conditions for conducting a deposition of a foreign-detained witness.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)