Case Summary (G.R. No. 176127)
Procedural History
Agbulos was arraigned on January 23, 1981, where he pleaded not guilty. Following the prosecution’s presentation of evidence, which was completed on April 25, 1984, Agbulos failed to appear at subsequent hearings, prompting a warrant for his arrest. Although a warrant was initially recalled due to incorrect notification to his bonding company, Agbulos once again failed to appear on November 5, 1984, leading to another order for his arrest and an order compelling the bonding company to show cause.
Trial and Judgment
The trial court issued a judgment against the bonding company for failing to produce Agbulos and subsequently rescheduled the trial. Despite multiple notifications, Agbulos did not attend the hearings. His defense adopted the testimony of a prosecution witness instead of presenting evidence. On June 15, 1985, the trial court found Agbulos guilty of forcible abduction with rape and sentenced him to reclusion perpetua, ordering him to pay P20,000 in indemnity to Bangit.
Validity of Trial in Absentia
The trial court's decision to proceed with the trial in absentia was valid under the 1973 Constitution as well as the 1987 Constitution. Article IV, Section 19 of the 1973 Constitution, which is mirrored in Article III, Section 14(2) of the 1987 Constitution, permits a trial to continue in the absence of the accused provided he has been notified and his absence is unjustified. This rule was enacted to expedite criminal proceedings and prevent defendants from evading justice through escape.
Impact of Accused's Escape
Agbulos' escape from custody was significant. The court determined that his failure to appear was unjustifiable due to his escape, effectively waiving his right to be present during the trial. Escaping custody serves as a waiver of rights, preventing an accused from delaying proceedings indefinitely. The principle that an accused can be tried in absentia aligns with the legal framework designed to deter manipulation of the judicial process by escapees.
Dismissal of Appeal
Agbulos’ appeal was dismissed as he had not surrendered nor returned to face the court after fleeing. According to Rule 124, Section 8 of the 1985 Rules of Criminal Procedure, a defendant who escapes or jumps bail forfeits their right to appeal unless they ret
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Case Overview
- The case involves the accused-appellant, Joselito Agbulos, who faced charges of forcible abduction with rape, filed by complainant Angelita P. Bangit.
- Agbulos was arraigned on January 23, 1981, entering a plea of not guilty.
- The prosecution rested its case on April 25, 1984, leading to subsequent events concerning the accused's absence during trial proceedings.
Timeline of Proceedings
- January 23, 1981: Agbulos arraigned, pleaded not guilty.
- April 25, 1984: Prosecution completed presenting its evidence.
- August 13, 1984: Arrest warrant issued due to Agbulos's failure to appear at scheduled hearings.
- September 24, 1984: Arrest order recalled due to notice being sent to the wrong bonding company.
- November 5, 1984: Agbulos again failed to appear; arrest ordered.
- December 18, 1984: Trial court ordered judgment against the bonding company for failing to produce Agbulos.
- January 30, 1985: Agbulos failed to appear once more; defense adopted prosecution witness's testimony.
- June 15, 1985: Trial court convicted Agbulos and sentenced him to reclusion perpetua, ordering him to indemnify the victim.
Judgment and Sentencing
- The trial court found Agbulos guilty of forcible abduction with rape an