Case Summary (G.R. No. 67301)
Petitioner
Manuel V. Bala, previously sentenced under the Indeterminate Sentence Law for falsification of a public document (Revised Penal Code, art. 172) and later placed on probation.
Respondents
Hon. Judge Antonio M. Martinez (RTC-Manila, Branch XX), the People of the Philippines, and Paul Ayang-Ang, Probation Officer, Manila Probation Office No. 4.
Key Dates
• January 3, 1978 – Trial court conviction of petitioner for falsification (Criminal Case No. 24443).
• April 9, 1980 – Court of Appeals affirms conviction.
• August 11, 1982 – RTC grants probation for one year.
• August 10, 1983 – Probation period nominally expires.
• December 8, 1983 – People file motion to revoke probation.
• April 2, 1984 – RTC-Manila denies petitioner’s motion to dismiss revocation proceedings.
• January 29, 1990 – Supreme Court issues decision.
Applicable Law
• 1987 Philippine Constitution (decision after 1990).
• Presidential Decree No. 968 (Probation Law of 1976), as amended by P.D. 1990 (non-retroactive).
• Revised Penal Code, Articles 171 and 172.
• Indeterminate Sentence Law.
Procedural Posture and Relief Sought
Petitioner filed a petition for certiorari and prohibition with preliminary injunction, challenging the RTC order of April 2, 1984, which denied his motion to dismiss or strike out the People’s motion to revoke his probation.
Factual and Procedural Background
After conviction and affirmation on appeal, the trial court granted Bala probation on August 11, 1982, subject to standard conditions—including residence restrictions and supervisory reporting. Although the one-year period lapsed on August 10, 1983, no final discharge order issued because the probation officer had not submitted his report.
Motion to Revoke and Petitioner’s Objection
On December 8, 1983, the People moved to revoke probation for alleged violations. Petitioner opposed, arguing that (a) his probation period had expired and (b) his change of residence to Las Piñas shifted jurisdiction to that court under P.D. 968, Section 13.
RTC’s Denial of Motion to Dismiss
Branch XX denied the motion to dismiss, finding merit in continuing revocation proceedings and retaining jurisdiction despite petitioner’s contentions.
Issue 1: Automatic Termination of Probation
Under P.D. 968, probation does not terminate automatically upon expiration of its term; a final discharge order based on the probation officer’s report is required (Section 16). Absent that order, probation subsists until discharged or revoked.
Issue 2: Jurisdiction and Transfer of Venue
Probation proceedings attach to the court that granted the probation. All branches of the RTC in the National Capital Judicial Region (Metro Manila) are co-equal; petitioner’s intra-region residence change did not divest RTC-Manila of jurisdiction.
Violations of Probation Conditions
The probation officer’s reports revealed that Bala (a) failed to comply with employment and supervision requirements, (b) committed
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Procedural History
- Petition for Certiorari and Prohibition, with request for Preliminary Injunction and/or Temporary Restraining Order, filed by petitioner Manuel V. Bala seeking to annul the RTC-Manila Branch XX order of April 2, 1984.
- Underlying Criminal Case No. 24443: conviction on January 3, 1978 for falsification of public document under Article 172, RPC; indeterminate sentence imposed.
- Appeal to the Court of Appeals; decision affirmed in toto on April 9, 1980.
- Grant of probation by RTC-Manila (then CFI) on August 11, 1982 for one year, subject to specified conditions.
- Motion to revoke probation filed by the People on December 8, 1983; opposition and related motions filed by petitioner in January 1984.
- RTC-Manila Branch XX denied petitioner’s motion to dismiss/strike out the revocation motion on April 2, 1984.
- Petition elevated to the Supreme Court; decision promulgated January 29, 1990.
Antecedent Conviction and Sentence
- Indicted for falsifying Maria Eloisa Criss Diazen’s passport picture with another person’s, thereby falsifying a genuine public document.
- RTC judgment (January 3, 1978) found guilt beyond reasonable doubt; imposed indeterminate penalty of 1 year & 1 day to 3 years & 6 months & 21 days prision correccional; fine of P1,800 with subsidiary imprisonment; credit for preventive detention.
- Court of Appeals affirmed conviction and sentence in April 1980; remand for execution of judgment.
Grant and Terms of Probation
- Probation application by petitioner granted August 11, 1982 by RTC-Manila Branch XX.
- Duration: one year from date of grant; conditions included:
- Gainful employment and productive societal membership.
- Cooperation with rehabilitation program and probation officer.
- Residence at BF Homes, Las Piñas, with no change or travel beyond Metro Manila over 24 hours without written approval.
- Final discharge contingent upon probation officer’s report and court order; no final discharge issued by August 10, 1983.
Motion to Revoke and Related Pleadings
- December 8, 1983: Assistant City Fiscal filed motion to revoke probation, alleging terms a