Case Summary (G.R. No. 154464)
Background of the Case
On December 7, 1993, Soriano was sentenced for his offenses, leading to his probation being granted on March 8, 1994. The terms of his probation notably included obligations to meet family responsibilities, maintain specific employment or engage in vocational training, and indemnify the heirs of the victim, Isidrino Daluyong, in the amount of P98,560.00.
Motion to Cancel Probation
On April 26, 1994, Assistant Prosecutor Benjamin A. Fadera filed a motion to cancel Soriano's probation, citing his failure to satisfy civil liability and his alleged commission of another crime. The Zambales Parole and Probation Office initially recommended allowing Soriano to continue probation, urging him to submit a payment program instead. The trial court directed him to submit a program for payment rather than immediately revoke his probation.
Early Violations and Trials
Nelda Da Maycong, the supervising officer, raised concerns regarding Soriano's failure to indemnify the victim’s heirs after discovering that Soriano's father received a substantial insurance payment related to the accident. Following manifestations from Da Maycong about these violations, on August 15, 1994, the court instructed Soriano again to submit a payment program.
Contempt of Court
Soriano subsequently filed a motion for reconsideration, stating he did not receive the previous order due to a failure of communication from his counsel. However, on October 4, 1994, the trial court found Soriano in contempt of court for his non-compliance with previous orders and revoked his probation, sentencing him to serve the original penalty.
Appeal to the Court of Appeals
Soriano challenged the trial court's order by filing a special civil action for certiorari to the Court of Appeals, alleging that the judge had abused discretion in revoking his probation based on his purported non-compliance. The Court of Appeals dismissed his petition, emphasizing Soriano's "stubborn unwillingness" to comply with court orders and reinforcing the legitimacy of revocation given his alleged violations.
Petitioner's Arguments
In his appeal, Soriano contended that he did not deliberately ignore the court's orders since he had not been informed promptly by his counsel, attributing his financial inability to comply with the payment requirement to poverty. He argued that conditioning probation on civil liability contravened the equal protection clause of the Constitution. He referenced previous decisions which suggested that conditions of probation should be reasonable and consider the probationer's capacity.
Response from the Solicitor General
The Solicitor General advocated for the dismissal of Soriano's petition, asserting that his violations justified the revocation of probation, noting that the case is distinct from precedents cited b
...continue readingCase Syllabus (G.R. No. 154464)
Case Citation
- G.R. No. 123936, March 04, 1999
- 363 Phil. 573
Parties Involved
- Petitioner: Ronald Soriano
- Respondents:
- Court of Appeals
- Hon. Rodolfo V. Toledano, Presiding Judge of the Regional Trial Court, Branch 69, Third Judicial Region, Iba, Zambales
- Provincial Sheriff, Third Judicial Region, Iba, Zambales
- Ms. Nelda Da Maycong, Supervising Parole and Probation Officer and Officer-in-Charge, Zambales Parole and Probation Office
- The People of the Philippines
Background of the Case
- Ronald Soriano was convicted of Reckless Imprudence resulting to homicide, serious physical injuries, and damage to property on December 7, 1993.
- His application for probation was granted on March 8, 1994, with specific conditions set by the trial court.
Conditions of Probation
- Among the terms imposed were:
- Family Responsibilities: He shall meet his family responsibilities.
- Employment: He must secure specific employment and cannot change it without prior notice to the supervising officer.
- Civil Liability: He is mandated to indemnify the heirs of the victim, Isidrino Daluyong, in the amount of P98,560.00.
Proceedings Leading to Contempt
- On April 26, 1994, a motion was filed by Assistant Prosecutor Benjamin A. Fadera to cancel Soriano's probation due to non-compliance with civil liabilities.
- A supplemental motion was filed alleging that Soriano was awaiting arraignment for another crime.
- The Zambales Parole and Probation Office recommended that Soriano be allowed to continue his probation but required to submit a payment program for his civil liability.
- On June 20, 1994, the trial court denied the motion to cancel probation but ordered Soriano to submit a payment program.
Violation and Contempt Declaration
- Probation Officer Nelda Da Maycong reported that Soriano’s father received P16,500.00 as insu