Case Summary (G.R. No. 30076)
Procedural History
On July 7, 1928, the petitioners were convicted in criminal case No. 8142 and subsequently informed of their judgment. On July 16, 1928, the petitioners submitted a written petition waiving their right to appeal and requested immediate transfer to Bilibid Prison. Following their personal appearance in court on July 17, 1928, the judge formally acknowledged their waiver, described it as a withdrawal of their right to appeal, and ordered their commitment to prison.
Subsequent Motion for Reconsideration
On July 18, 1928, the petitioners, realizing the implications of their waiver, filed a motion asking the court to reconsider the order denying their appeal. They argued that their waiver stemmed from desperation related to their family circumstances. They expressed a hope for reduced penalties upon appeal and emphasized the emotional toll of their conviction and potential imprisonment on their lives.
Court's Denial of Motion
The motion was heard on July 21, 1928, wherein the judge denied it, stating that the petitioners had previously confirmed their waiver in court. He noted that they failed to provide satisfactory reasons for their sudden change of heart regarding the appeal. Consequently, the lower court concluded that it lacked jurisdiction to accept their appeal due to their prior voluntary waiver.
Legal Precedents and Analysis
In evaluating the case, the court referenced the legal doctrine from Macali v. Revilla and Ocampo, affirming that while defendants may be convicted after waiving their right to appeal, courts must ensure that defendants understand the implications of such waivers. The court assessed that the petitioners had sufficient time to consider their waiver and were informed of its consequences before proceeding with their voluntary commitment to prison.
Jurisdiction and Execution of Sentences
The court further clarified that once a defendant begins serving a sentence, as the petitioners had in this case, the court could not later reinstate their right to appeal. Following the legal principles established in Gregorio v. Director of Prisons, the court reiterated that compliance with a sente
...continue readingCase Syllabus (G.R. No. 30076)
Case Overview
- This case is a mandamus proceeding initiated by petitioners Fausta Lanestosa and Bernabe Lames against Francisco Santamaria, the Judge of the First Instance of Iloilo.
- The petitioners sought an order from the court to compel the respondent judge to admit their appeal, which was previously waived following their conviction for the crime of resistance to authority.
Factual Background
- On July 7, 1928, the petitioners were informed of their conviction in criminal case No. 8142, resulting in sentences of one year and eight months and four years imprisonment, respectively.
- Subsequently, on July 16, 1928, the petitioners, along with two other prisoners, submitted a written petition waiving their right to appeal and requesting immediate transfer to Bilibid Prison.
- The court, after hearing the petitioners, formally acknowledged their waiver of the right to appeal and ordered their commitment to Bilibid Prison on July 17, 1928.
Motion for Reconsideration
- On July 18, 1928, the petitioners filed a motion for reconsideration of the court’s order, expressing their desire to withdraw the waiver of their right to appeal.
- They cited several