Case Digest (G.R. No. 58652)
Facts:
Alfredo Rodillas y Bondoc v. The Honorable Sandiganbayan and The People of the Philippines, G.R. No. 58652, May 20, 1988, the Supreme Court En Banc, Gutierrez, Jr., J., writing for the Court.Petitioner Alfredo Rodillas y Bondoc was a patrolman of the Integrated National Police assigned to the jail section of Caloocan City and was tasked on March 27, 1980 to escort detention prisoner Zenaida Sacris de Andres from the City Jail to the Court of First Instance, Branch XXXIV, for trial on alleged violations of the Dangerous Drugs Act. The policewoman assigned to escort the detainee was ill, so petitioner performed the escort duty. While waiting at the Genato Building for the judge, petitioner allowed the detainee to speak with her husband at the request of a co‑officer; after the hearing was deferred, petitioner also allowed the detainee and her relatives to take lunch at the courthouse canteen.
During lunch the detainee asked to use the ladies' comfort room; petitioner accompanied her and another woman companion and stood guard outside the comfort room door. The companion left purportedly to buy sanitary napkins; after about ten minutes petitioner entered the comfort room and found the detainee had escaped through a window without grills onto a concrete eave. Petitioner observed the egress, searched the building with a co‑worker, then went to the detainee’s house and later to Nueva Ecija; he only formally reported the escape to superiors in the evening. Petitioner admitted not inspecting the comfort room before allowing entry and claimed lack of training in prisoner delivery.
Petitioner was charged under Article 224 of the Revised Penal Code (evasion through negligence / infidelity in custody of prisoner). The Sandiganbayan found him guilty beyond reasonable doubt and imposed the penalty of four months and one day of arresto mayor, eight years and one day of temporary special disqualification, and costs. Petitioner challenged the conviction before the Supreme Court, raising two assignments of error: (1) that the conviction rested only on his admissions without inde...(Pro-only)
Issues:
- Whether petitioner’s conviction, allegedly based chiefly on his admissions, may stand absent separate proof of negligence.
- Whether petitioner’s acts amounted to the degree of negligence—“definite laxity all but amounting to deliberate non‑performance of duty”—required to convict under Article 224 of ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)