Case Summary (G.R. No. 184091)
Background of the Case
The RTC conviction of the petitioners occurred after they failed to appear multiple times during trial and at the promulgation of judgments. On September 3, 2007, the RTC issued a decision convicting them while they were absent despite having received proper notices about the trial dates. Subsequently, the RTC issued warrants for their arrest after they consistently failed to participate in court proceedings.
Procedural History
On October 11, 2007, the petitioners filed notices of appeal claiming they were unaware of the promulgation due to a transfer to another police station. The RTC denied their appeals on November 20, 2007, ruling that they had neglected their duty to inform the court of their address changes, thereby losing their standing in court.
Subsequent Motions and RTC Decisions
Afterward, PO3 Macalinao successfully moved for reconsideration and his notice of appeal was granted. However, the petitioners' joint motion for reconsideration was denied, with the RTC highlighting that they had not validly justified their absences, unlike PO3 Macalinao who provided adequate evidence regarding his transfer.
Petition for Certiorari
The petitioners sought relief via a petition for certiorari under Rule 65, which was initially dismissed by the Court of Appeals (CA) for procedural defects. Upon reconsideration, the CA determined that the petitioners failed to demonstrate any grave abuse of discretion by the RTC in denying their notices of appeal.
Arguments Presented by Petitioners
The petitioners contended that their appeals contained valid explanations for their non-appearance and that their notices sufficiently complied with the requirements of the Rules of Court. They further asserted that there was no mandatory requirement obliging them to have their bench warrants lifted prior to appealing their conviction.
Legal Analysis and Decision
The Supreme Court emphasized that an appeal presupposes the appellant’s standing in court. The petitioners’ failure to appear constituted a loss of standing due to their unjustified absence at the promulgation of judgment. Furthermore, the Court noted that the petitioners failed t
...continue readingCase Syllabus (G.R. No. 184091)
Case Background
- This case is a petition for review on certiorari filed under Rule 45 of the Rules of Court.
- Petitioners: Police Inspector Edward Garrick Villena and Police Officer 1 Percival Doroja, along with several other police officers, were indicted for robbery (extortion) in the Regional Trial Court (RTC) of Las Piñas City.
- The trial court case number is Criminal Case No. 05-0025.
- During the trial, petitioners failed to present evidence in their defense, with only PO3 Reynaldo Macalinao appearing.
RTC Conviction
- On August 29, 2007, the RTC convicted the petitioners and other co-accused of the crime charged.
- The promulgation of judgment occurred on September 3, 2007, during which the petitioners again failed to appear despite proper notices sent to their recorded addresses.
- The RTC issued warrants for their arrest due to their absence.
Notices of Appeal
- On October 11, 2007, the petitioners, through new counsel Atty. William F. delos Santos, filed separate notices of appeal, claiming they did not receive notice of the promulgation because they had been transferred to another police station.
- The RTC denied due course to these notices of appeal, citing that all necessary notifications were sent to their last known addresses and returned undelivered.
RTC's Rationale
- The RTC emphasized the petitioners’ obligation to inform the court of any changes in their addresses to ensure proper notification.
- Their failure to appear during trial and the promulgation of judgment resulted in