G.R. No. 184091 - Villena vs. People

The case involved petitioners P/Insp. Edward Garrick Villena and PO1 Percival Doroja, along with other police personnel, who were indicted for the crime of robbery (extortion) before Regional Trial Court (RTC), Branch 202, Las Piñas City.
The docketed criminal case, Criminal Case No. 05-0025, proceeded to trial after the accused all pled “not guilty” during the arraignment. Only PO3 Reynaldo Macalinao appeared during trial to present his evidence, while the other petitioners did not show up to adduce any evidence in their defense.

The RTC rendered its decision on August 29, 2007, convicting petitioners along with other co-accused.
On September 3, 2007, the judgment was promulgated in absentia (since the petitioners failed to appear even though proper notices and subpoenas were sent), leading the court to issue warrants of arrest under the rules on criminal procedure for their non-appearance.
Petitioners explained their absence by claiming they did not receive notice of the promulgation due to being transferred to a different police station; however, documentary evidence of such transfer was only produced by PO3 Macalinao, who had consistently attended the trial hearings.

On October 11, 2007, petitioners, through new counsel, filed separate notices of appeal before the RTC, explaining their failure to attend the promulgation was because they had not been properly notified as their addresses had changed.
The RTC, in its November 20, 2007 Order, denied due course to these notices of appeal, emphasizing that the accused had an obligation to update their addresses to ensure receipt of court communications.
Subsequent motions for reconsideration were filed: PO3 Macalinao’s motion was granted (allowing his appeal to be entertained) while the motions of PO1 Doroja and P/Insp. Villena were denied due to their failure to adduce a valid or compelling reason for their non-appearances during critical stages of the trial.

Petitioners initiated a petition for certiorari, prohibition, and mandamus under Rule 65 alleging that the CA erred in dismissing their petition and in upholding the RTC’s decision denying their notice of appeal.
The CA, through its Resolutions dated April 30, 2008 and August 1, 2008, found that the petitioners did not provide sufficient proof that their failure to appear was excusable and that their filing of notices of appeal did not amount to a valid act of surrender, given their failure to comply with the prescribed requirements.

The court underscored that the accused have a duty to inform the RTC of any change in address to ensure proper service of notices, subpoenas, and court processes.
The evidentiary record showed that only PO3 Macalinao demonstrated sufficient interest in defending his case by continuously attending hearings and providing proper documentation regarding his transfer, whereas the others did not.
The failure to physically surrender or appear at the promulgation of judgment signified a loss of standing in court, resulting in the forfeiture of their statutory right to appeal.

Whether petitioners’ failure to appear during the promulgation of judgment, and their subsequent reliance on filing notices of appeal as grounds for regaining standing, complied with the mandatory requirements under Section 6, Rule 120 of the Rules of Court.

Whether the alleged non-receipt of notice, purportedly due to change of address, constitutes a justifiable and excusable cause for their non-appearance at the scheduled promulgation of judgment.

Whether the actions and omissions of petitioners, including their failure to surrender or properly inform the court of their change in address, automatically resulted in the loss of their right to seek appeal remedies.

Whether the Court of Appeals erred in affirming the RTC’s decision in denying petitioners’ notices of appeal and in dismissing their subsequent motions for reconsideration.