Case Summary (G.R. No. 116512)
Case Background
The Supreme Court, in its resolution dated July 30, 1996, ruled that the conditional pardons granted to Casido and Alcorin were void because they were issued while their appeal was pending, violating the constitutional provision that prohibits the granting of pardons before a final conviction. This ruling led to the denial of the accused-appellants' urgent motion to withdraw their appeal and mandated their re-arrest and reconfinement at the New Bilibid Prison.
Presidential Committee for the Grant of Bail, Release, or Pardon
The background of the conditional pardon process involved the establishment of a Presidential Committee for the Grant of Bail, Release, or Pardon, created under the administration of President Fidel V. Ramos in 1992. The committee, which included members from various government departments, was directed to establish guidelines for granting clemency, particularly in cases involving charges related to national security and public order.
Procedure of Granting Pardon
In the wake of the committee's guidelines, a Secretariat was formed to evaluate and recommend applications for pardon, release, or bail. The Secretariat, which included representatives from various governmental agencies, had an understanding with non-governmental organizations (NGOs) to ensure that motions for the withdrawal of appeals would be filed concurrently with applications for clemency.
Miscommunication and Misinterpretation of Guidelines
An essential aspect of the case stemmed from miscommunication regarding the applicants' appeals. The Secretariat believed in good faith that the counsel representing Casido and Alcorin would fulfill the agreed-upon requirement of withdrawing their appeals before the pardon was recommended to the President. However, this proved to be based on a verbal commitment and not adequately documented.
Judicial Considerations and the Concept of Amnesty
The Court further examined the distinction between pardon and amnesty, clarifying that the latter negates the criminal liability for actions committed in pursuit of political beliefs. The amnesty applied to Casido and Alcorin was valid and effectively nullified the issues arising from the conditional pardon; thus, their release is justified on amnesty grounds rather than the void pardon.
Admonition to the Presidential Committee
Despite the validity of the amnesty, the members of the Presidential Committe
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Case Citation
- G.R. No. 116512
- 336 Phil. 344; 94 OG No. 6, 917 (February 9, 1998)
- Decision Date: March 07, 1997
- Court: Third Division
Parties Involved
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellants: William O. Casido @ aMario, Franklin A. Alcorin @ aArman
Background of the Case
- The case revolves around the conditional pardon granted to accused-appellants William Casido and Franklin Alcorin, which was declared void by the court due to its issuance during the pendency of their appeal.
- The accused-appellants had filed an urgent motion to withdraw their appeal, which was received by the Supreme Court prior to their conditional pardon.
Key Legal Issues
- The legality of the conditional pardon granted during the appeal process.
- The implications of the Presidential Committee for the Grant of Bail, Release or Pardon’s (PCGBRP) actions in recommending the pardon.
- The distinction between pardon and amnesty as legal concepts.
Court's Resolution
- The court denied the accused-appellants' motion to withdraw their appeal.
- Directed the Bureau of Corrections, with the Philippine National Police's support, to re-arrest the accused-appellants and reconfine them at the New Bilibid Prisons, within 60 days of notice.
- Suspended further action on the appeal until re-arrest was executed.
- Required the members of the Presidential Committee to show cause for their actions that led to the recommendation of the pardon despite the pending appeal.