Title
Reyes vs. People
Case
G.R. No. 193034
Decision Date
Jul 20, 2015
Rodging Reyes allegedly threatened Salud Gegato in 2001; charged with Grave Threats, courts modified to Light Threats. CA dismissed Reyes’ petition for procedural lapses; SC affirmed, stressing rule adherence.

Case Summary (G.R. No. 193034)

Case Background

Rodging Reyes was charged with Grave Threats under Article 282 of the Revised Penal Code in a complaint filed by Salud M. Gegato. The complaint stemmed from a telephone threat made by Reyes against Gegato, which he allegedly uttered at Avon Store in Bayugan, Agusan del Sur. Reyes asserted that the threats were made out of personal resentment, intending to instill fear in Gegato.

Procedural History

Before arraignment, Reyes filed a Motion to Quash based on jurisdiction and the classification of threats, claiming that the incident constituted Other Light Threats under Article 285 instead of Grave Threats. The Municipal Circuit Trial Court (MCTC) denied the motion, and subsequent attempts for reconsideration were likewise denied. Reyes also filed a Motion to Inhibit the presiding judge due to Gegato's status as court interpreter, which was rejected as lacking basis for disqualification.

MCTC Decision

On August 10, 2005, the MCTC found Reyes guilty of Grave Threats, sentencing him to imprisonment for two months and ordering him to pay moral damages and litigation costs to Gegato.

Regional Trial Court Appeal

Reyes appealed to the Regional Trial Court (RTC), which ultimately modified the initial ruling on April 2, 2007, finding him guilty of Other Light Threats instead, adjusting the imprisonment duration and reducing the moral damages awarded to Gegato, while maintaining the attorney's fee.

Subsequent Appeals

The petitioner struggled to file a timely Petition for Review before the Court of Appeals. His first Motion for Extension was denied due to incomplete payment of docket fees, and a second request for extension was similarly denied for lacking sufficient reason and documentation. The petition was dismissed for being filed beyond the reglementary period and for other procedural deficiencies.

Court of Appeals Resolution

The CA's November 23, 2009 resolution dismissed Reyes' second Motion for Reconsideration, emphasizing compliance with procedural standards for filing appeals. The resolution determined that Reyes' subsequent motions for reconsideration were prohibited by the Rules of Court as they were considered mere reiterations of previous arguments.

Supreme Court's Decision

The Supreme Court upheld the dismissal of Reyes' petition for lack

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