Case Summary (G.R. No. 116512)
Applicable Law and Procedural History
The applicable law derives from the 1987 Philippine Constitution, particularly the provisions regarding the limitations on presidential pardons and clemency, as well as prior decisions of the Supreme Court that guide the application of these constitutional provisions. The procedural history reflects an appeal by the accused, initiated with a supplemental notice of appeal filed on December 8, 1993. The appellate court ultimately accepted the appeal and scheduled a series of submissions from both the defense and the prosecution.
Motion to Withdraw Appeal
On January 11, 1996, the accused-appellants filed an undated urgent motion to withdraw their appeal. This motion was notable for lacking substantive reasons for the withdrawal. An indorsement from Venancio J. Tesoro, Superintendent IV of the Bureau of Corrections, conveyed that the appellants were informed of the legal implications of their motion and that it was made voluntarily.
Conditional Pardon and Its Legal Standing
Subsequent to the motion to withdraw being filed, documentation indicated that both accused-appellants were granted conditional pardons on January 19, 1996, and released from prison on January 25, 1996. However, the pardons were granted during the pendency of their appeal, raising significant legal concerns regarding their validity under established jurisprudence. The resolutions from previous cases indicated that a pardon, whether full or conditional, cannot be granted if an appeal is still ongoing.
Court's Ruling on the Conditional Pardon
The court declared the conditional pardons granted to Casido and Alcorin as void, reinforcing that such clemency during the pendency of an appeal violates the principle established in the 1987 Constitution and various resolutions from prior cases. Specifically, the court pointed to the necessity of a final judgment before any form of clemency could be considered, thereby rendering the actions of the Presidential Committee for the Grant of Bail, Release, and Pardon as illegal in this context.
Directive for Re-arrest and Future Action
As a result of the findings, the co
...continue readingCase Syllabus (G.R. No. 116512)
Case Overview
- The case involves the appeal of William Casido and Franklin Alcorin against the judgment of the Regional Trial Court (RTC) of Negros Oriental, Branch 45 (Bais City), in Criminal Case No. 397-B.
- On December 1, 1993, the RTC found the accused guilty beyond reasonable doubt of murder, sentencing each to reclusion perpetua and ordering them to pay damages amounting to P200,000.00 and P25,000.00 for actual damages and funeral expenses, respectively.
- The accused filed a supplemental notice of appeal on December 8, 1993.
Procedural History
- The appeal was accepted by the Supreme Court on December 7, 1994.
- The accused-appellants submitted their "Appellants Brief" on June 30, 1995, while the Office of the Solicitor General filed the Brief for the Appellee on September 28, 1995, urging for the affirmance of the RTC decision.
- An urgent motion to withdraw the appeal was filed by the accused-appellants on January 11, 1996, without stating reasons.
- The motion was referred to the court with an indorsement from the Bureau of Corrections, indicating that the accused understood the legal implications and acted of