Case Digest (G.R. No. 103174)
Facts:
Amado B. Teodoro v. Court of Appeals and People of the Philippines, G.R. No. 103174, July 11, 1996, promulgated August 18, 1997, Supreme Court Second Division, Mendoza, J., writing for the Court.Petitioner Amado B. Teodoro was vice‑president and corporate secretary of DBT‑Marbay Construction, Inc.; complainant Carolina Tanco‑Young was the corporation’s treasurer. Petitioner is the brother of the corporation’s president, Donato Teodoro; complainant is the daughter of the board chairman, Agustin Tanco. On August 17, 1984, a boardroom confrontation occurred over a disputed document that petitioner, as secretary, sought to have signed by the chairman. During the exchange, complainant allegedly called petitioner a “falsifier,” and petitioner slapped her; her father attempted to lunge at petitioner, and the daughter embraced her father to prevent a fight. Complainant was then seven months pregnant.
The Metropolitan Trial Court (MeTC) of Mandaluyong found petitioner guilty of simple slander by deed and imposed a P110 fine. Petitioner appealed to the Regional Trial Court (RTC) of Pasig. While the appeal in the RTC was pending, petitioner filed a motion to withdraw his appeal (June 6, 1985) and paid the P110 fine (July 16, 1985). The RTC denied the motion to withdraw (July 26, 1985), reasoning the appeal had been perfected and the prosecution had already submitted its memorandum; a motion for reconsideration was denied (Nov. 11, 1985). On February 12, 1986, the RTC rendered judgment finding petitioner guilty of grave slander by deed and sentenced him to three months of arresto mayor, considering the victim’s pregnancy and emotional vulnerability.
Petitioner elevated the RTC decision to the Court of Appeals by petition for review; the Court of Appeals dismissed the petition (Nov. 27, 1987) and denied reconsideration. Petitioner then filed a petition for review on certiorari before the Supreme Court (Rule 45), challenging (a) the RTC’s denial of his motion to wit...(Subscriber-Only)
Issues:
- Did the Regional Trial Court abuse its discretion in denying petitioner’s motion to withdraw his appeal from the Metropolitan Trial Court?
- Did petitioner’s payment of the P110 fine imposed by the Metropolitan Trial Court render that judgment final and thus bar the RTC from imposing a greater penalty (i.e., did it give rise to double jeopardy)?
- If the RTC properly found grave slander by deed, what is the appropriate penalty i...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)