People v. Casido

G.R. No. 116512 (July 30, 1996)

Facts:

The case involves accused-appellants William Casido and Franklin Alcorin, who were convicted of murder by the Regional Trial Court (RTC) of Negros Oriental, Branch 45, in Criminal Case No. 397-B. They were sentenced to reclusion perpetua and ordered to pay damages amounting to P200,000.00 and P25,000.00 for funeral expenses. Following their conviction, the accused filed a supplemental notice of appeal on December 8, 1993, which was accepted by the Supreme Court on December 7, 1994.

On January 11, 1996, the accused-appellants submitted an undated urgent motion to withdraw their appeal, without providing reasons for this request. The motion was accompanied by an indorsement from Venancio J. Tesoro, Superintendent IV of the Bureau of Corrections, indicating that the legal implications of the withdrawal had been explained to the accused and that the motion was filed voluntarily.

Subsequently, on March 18, 1996, the Court received an indorsement stating that the accused-appellants had been released on conditional pardon on January 25, 1996. The conditional pardons were granted by the President on January 19, 1996, during the pendency of their appeal. The Court noted that the practice of granting pardons while an appeal is pending is a violation of established legal principles.

Legal Issues:

1. Whether the conditional pardons granted to the accused-appellants during the pendency of their appeal are valid.
2. The implications of the withdrawal of the appeal in light of the conditional pardons.
3. The administrative liability of officials involved in the processing of the pardons.

Arguments:

• For the Accused-Appellants: The accused-appellants argued for the withdrawal of their appeal, presumably seeking to benefit from the conditional pardons granted to them. They did not provide specific reasons for the withdrawal but relied on the legal advice they received regarding the implications of their motion.

• For the Plaintiff-Appellee (People of the Philippines): The prosecution contended that the conditional pardons were invalid as they were granted during the pendency of the appeal, which is contrary to established jurisprudence. The prosecution emphasized that the law prohibits the granting of pardons while an appeal is ongoing, and thus, the accused-appellants should be re-arrested and reconfined.

Court's Decision and Legal Reasoning:

The Supreme Court ruled that the conditional pardons granted to William Casido and Franklin Alcorin were void because they were issued during the pendency of their appeal. The Court reiterated its previous rulings, particularly in the cases of People vs. Hinlo and People vs. Salle, which established that a conviction must be final before a pardon can be granted. The Court emphasized that any application for pardon should not be processed while an appeal is pending, and that the acceptance of a pardon does not equate to the abandonment of an appeal.

The Court denied the motion to withdraw the appeal and directed the Bureau of Corrections to re-arrest the accused-appellants and reconfine them. Additionally, the Court required the officers of the Presidential Committee for the Grant of Bail, Release, and Pardon to show cause why they should not be held in contempt for processing the pardons despite the ongoing appeal.

Significant Legal Principles Established:

1. Finality of Conviction: A conditional pardon cannot be granted while an appeal is pending, as a conviction must be final for a pardon to be valid.
2. Administrative Liability: Officials involved in the processing of pardons during the pendency of an appeal may be held administratively liable for their actions.
3. Prohibition of Pardon Processing: The Court established a clear prohibition against the processing of pardon applications while an appeal is active, reinforcing the need for a final judgment before any clemency can be granted.