Case Digest (G.R. No. 58652)
Facts:
In Alfredo Rodillas y Bondoc v. Sandiganbayan (244 Phil. 366, May 20, 1988), petitioner Alfredo Rodillas y Bondoc, then a patrolman assigned to the Caloocan City Jail, 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, at the Genato Building in Caloocan City and back. Upon arrival at the courtroom, Rodillas allowed the prisoner to speak with her husband and later joined them for lunch at the court’s mezzanine canteen. Thereafter, he accompanied Zenaida and a female companion to the women’s comfort room on the second floor but failed to inspect the room for escape routes before standing guard outside. The companion left on the pretext of buying sanitary napkins and never returned; shortly thereafter, Zenaida had fled through an ungrilled window. Rodillas spent the day searching for her—first locally, then in Nueva Ecija—without reporting the escape until evening. The Sandiganbayan fouCase Digest (G.R. No. 58652)
Facts:
- Background
- Alfredo Rodillas y Bondoc, a Patrolman of the Integrated National Police Force assigned to the Caloocan City Jail section, was charged under Art. 224, Revised Penal Code, for “Evasion through Negligence.”
- The information alleged that on March 27, 1980, he had custody of Zenaida Sacris de Andres, a detention prisoner, and, through negligence, allowed her to escape.
- Circumstances of the Escape
- Escort to Court and Deviation
- Petitioner escorted the detainee to Branch XXXIV, CFI Caloocan, and permitted her to talk with her husband and to take lunch at the mezzanine canteen.
- After adjournment, he accompanied the detainee and a lady companion to the ladies’ comfort room on the second floor without first inspecting for possible egress points.
- Actual Escape and Aftermath
- Left standing guard, he waited over ten minutes after the companion exited to buy sanitary napkins; upon entry he found the window ungrilled and the detainee gone.
- He searched Caloocan and Nueva Ecija in civilian vehicles and only formally reported the escape to his superiors late that evening.
Issues:
- Whether the Sandiganbayan properly convicted petitioner based solely on his admissions without independent proof of negligence.
- Whether petitioner’s conduct—permitting lunch and a toilet break without precautions—constituted “definite laxity” amounting to deliberate non-performance of duty under Art. 224.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)