Case Digest (G.R. No. 240053)
Facts:
People of the Philippines v. Maria Cristina P. Sergio and Julius L. Lacanilao, G.R. No. 240053, October 21, 2024, Supreme Court Special Third Division, Hernando, J., writing for the Court.Mary Jane Veloso was arrested in Yogyakarta, Indonesia for carrying 2.6 kilograms of heroin, convicted of drug trafficking under Indonesian law and sentenced to death. She had traveled to Indonesia on the false promise of work abroad made by respondents Maria Cristina P. Sergio (Cristina) and Julius L. Lacanilao (Julius). In the Philippines Cristina and Julius were charged with Qualified Trafficking in Persons (under RA 9208), Illegal Recruitment (under RA 8042), and Estafa (Revised Penal Code).
Philippine prosecutors, considering Mary Jane an essential witness, requested Indonesia to suspend execution so her testimony could be taken for the Philippine criminal case; Indonesia agreed but conditioned cooperation on Mary Jane remaining in Indonesian territory and that all questions be submitted in writing. Faced with those terms, the prosecution sought to take Mary Jane’s testimony by deposition upon written interrogatories under Rules 23 and 25 of the Revised Rules of Court.
The Regional Trial Court (RTC), Branch 88, Sto. Domingo, Nueva Ecija granted leave for the deposition by written interrogatories and set detailed procedures: submission and ruling on proposed direct questions and defense objections; taking the deposition in Yogyakarta with the presiding judge or the Consul propounding final questions; verbatim transcription by consular staff; opportunity for defense cross-interrogatories with corresponding timelines; and procedure for redirect questions, among other mechanics. Cristina and Julius filed a petition for certiorari with the Court of Appeals (CA) challenging the RTC’s grant.
The CA granted the petition, finding the RTC had gravely abused its discretion and reversing the RTC. The prosecution appealed to the Supreme Court; on October 9, 2019 the Supreme Court reversed the CA and reinstated and affirmed the RTC’s resolution insofar as it allowed the taking of Mary Jane’s testimony by deposition upon written interrogatories, with modification that the deposition be taken before Philippine consular officials in Indonesia. That October 9, 2019 Decision became final on March 4, 2020.
Subsequently the Office of the Solicitor General (OSG) filed an Urgent Omnibus Motion seeking supplementation of the October 9, 2019 Decision to provide specific operational instructions after receiving new conditions from the Government of Indonesia (letter dated December 4, 2020) stating that (a) the deposition should be conducted ...(Subscriber-Only)
Issues:
- May the Supreme Court amend or supplement its final and executory October 9, 2019 Decision by entertaining the OSG’s Urgent Omnibus Motion to prescribe additional, specific procedures for taking Mary Jane Veloso’s deposition?
- If the Court cannot alter its final Decision, what is the proper scope of judicial action regarding the implementation modalities of an approved deposition where the requested (foreign) ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)