People Vs Mateo

THE PEOPLE OF THE PHILIPPINES, appellee, vs.
EFREN MATEO y GARCIA,

appellant
G.R. Nos. 14767887, July 7, 2004
Vitug, J.
Where life and liberty are at stake, all possible avenues to determine his
guilt or innocence must be accorded an accused, and no care in the
evaluation of the facts can ever be overdone. A prior determination by the
Court of Appeals on, particularly, the factual issues, would minimize the
possibility of an error of judgment. If the Court of Appeals should affirm the
penalty of death, reclusion perpetua or life imprisonment, it could then
render judgment imposing the corresponding penalty as the circumstances
so warrant, refrain from entering judgment and elevate the entire records of
the case to the Supreme Court for its final disposition.
On October 30, 1996, ten (10) informations, one for each count of rape, were
filed against appellant Efren Mateo. The lower court found Mateo guilty
beyond reasonable doubt, imposing the penalty of reclusion perpetua. The
Solicitor General, however, assails the factual findings of the trial court and
recommends an acquittal of the appellant.
Issue:
Whether or not the case should directly be forwarded to the Supreme Court
by virtue of the express provision in the constitution on automatic appeal
where the penalty imposed is reclusion perpetua, life imprisonment or death.
Held:
The case is REMANDED, and all pertinent records are ordered to be
forwarded to the Court of Appeals for appropriate action and disposition.
Up until now, the Supreme Court has assumed the direct appellate
review over all criminal cases in which the penalty imposed is death,
reclusion perpetua or life imprisonment (or lower but involving offenses
committed on the same occasion or arising out of the same occurrence that
gave rise to the more serious offense for which the penalty of death,
reclusion perpetua, or life imprisonment is imposed). The practice finds
justification in the 1987 Constitution
Article VIII, Section 5. The Supreme Court shall have the following
powers:
(2) Review, revise, reverse, modify, or affirm on appeal or
certiorari, as the law or the Rules of Court may provide, final
judgments and orders of lower courts in:
(d) All criminal cases in which the penalty imposed is reclusion
perpetua or higher.
The same constitutional article has evidently been a thesis for Article
47 of the Revised Penal Code, as amended by Section 22 of Republic Act No.
7659, as well as procedural rules contained in Section 3 of Rule 122, Section
10 of Rule 122, Section 13 of rule 124 and Section 3 of Rule 125 of the Rules
of Court. It must be stressed, however, that the constitutional provision is not
preclusive in character, and it does not necessarily prevent the Court, in the
exercise of its rule-making power, from adding an intermediate appeal or
review in favor of the accused.
In passing, during the deliberations among the members of the Court,
there has been a marked absence of unanimity on the crucial point of guilt or
innocence of herein appellant. Some are convinced that the evidence would
appear to be sufficient to convict; some would accept the recommendation of
acquittal from the Solicitor General on the ground of inadequate proof of guilt
beyond reasonable doubt. Indeed, the occasion best demonstrates the
typical dilemma, i.e., the determination and appreciation of primarily factual
matters, which the Supreme Court has had to face with in automatic review
cases; yet, it is the Court of Appeals that has aptly been given the direct
mandate to review factual issues.
While the Fundamental Law requires a mandatory review by the
Supreme Court of cases where the penalty imposed is reclusion perpetua, life
imprisonment, or death, nowhere, however, has it proscribed an
intermediate review. If only to ensure utmost circumspection before the
penalty of death, reclusion perpetua, or life imprisonment is imposed, the
Court now deems it wise and compelling to provide in these cases a review
by the Court of Appeals before the case is elevated to the Supreme Court.
Where life and liberty are at stake, all possible avenues to determine his guilt
or innocence must be accorded an accused, and no care in the evaluation of
the facts can ever be overdone. A prior determination by the Court of
Appeals on, particularly, the factual issues, would minimize the possibility of
an error of judgment. If the Court of Appeals should affirm the penalty of
death, reclusion perpetua, or life imprisonment, it could then render
judgment imposing the corresponding penalty as the circumstances so
warrant, refrain from entering judgment and elevate the entire records of the
case to the Supreme Court for its final disposition.
Statistics would disclose that within the eleven-year period since the
re-imposition of the death penalty law in 1993 until June 2004, the cases
where the judgment of death has either been modified or vacated consist of
an astounding 71.77% of the total of death penalty cases directly elevated
before the Court on automatic review that translates to a total of six hundred
fifty-one (651) out of nine hundred seven (907) appellants saved from lethal
injection. Under the Constitution Article VIII, Section 5, the power to amend
rules of procedure is constitutionally vested in the Supreme Court.
Procedural matters, first and foremost, fall more squarely within the
rule-making prerogative of the Supreme Court than the law-making power of
Congress. The rule here announce additionally allowing an intermediate
review by the Court of Appeals, a subordinate appellate court, before the
case is elevated to the Supreme Court on automatic review, is such a
procedural matter.
Pertinent provisions of the Revised Rules on Criminal Procedure, more
particularly Section 3 and Section 10 of Rule 122, Section 13 of rule 124,
Section 3 of rule 125, and any other rule insofar as they provide for direct
appeals from the Regional Trial Courts to the Supreme Court in cases where
the penalty imposes is death, reclusion perpetua, or life imprisonment, as
well as the resolution of the Supreme Court en banc, dated 19 September
1995, in Internal Rules of the Supreme Court in cases similarly involving
the death penalty, are to be deemed modified accordingly.
Case Remanded.

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THE PEOPLE OF THE PHILIPPINES, appellee, vs.

EFREN MATEO y GARCIA,

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