G.R. No. 144332; June 10, 2004
PEOPLE OF THE PHILIPPINES, petitioner, vs. COURT OF APPEALS (ELEVENTH DIVISION), EFREN S. ALMUETE, JOHNNY ILA y RAMEL and JOEL LLOREN y DELA CRUZ, respondents.

FACTS

Respondents Efren Almuete, Johnny Ila, and Joel Lloren were charged with violating Presidential Decree No. 705 (Forestry Code) for illegally transporting sawn timber. After trial, the Regional Trial Court (RTC) set the promulgation of its decision. On the scheduled date, only counsel appeared, informing the court that Almuete and Lloren were ill and presenting a medical certificate, and that Ila was absent due to lack of notice. The trial court deemed the absence unjustified, proceeded with the promulgation in absentia, found all three guilty, and sentenced them to imprisonment, also cancelling their bail bonds.
The respondents filed a motion for reconsideration, arguing they were deprived of their right to be present at promulgation. The RTC denied the motion. They then filed a petition for certiorari with the Court of Appeals (CA). The CA granted the petition, ordering the acquittal of Almuete for insufficiency of evidence and directing a re-promulgation of the decision for Ila and Lloren. The People of the Philippines elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the Court of Appeals erred in granting the petition for certiorari, specifically in ordering the acquittal of Almuete and a re-promulgation for Ila and Lloren.

RULING

The Supreme Court granted the petition, reversing the Court of Appeals and reinstating the RTC’s decision and order. The Court held that the trial court did not commit grave abuse of discretion in promulgating the decision in absentia. For promulgation in absentia to be valid, the accused must have been duly notified or their failure to appear is unjustified. Here, the medical certificate for Almuete and Lloren was issued by a private practitioner, not a government physician, and the trial court validly exercised its discretion in finding it insufficient to justify absence. For Ila, his claim of lack of notice was unsubstantiated. Furthermore, their subsequent evasion of arrest reinforced the conclusion that their absence was deliberate to avoid an adverse judgment.
Regarding the CA’s acquittal of Almuete, the Supreme Court ruled that the appellate court overstepped its authority in a certiorari proceeding under Rule 65. A writ of certiorari only corrects jurisdictional errors or grave abuse of discretion amounting to lack or excess of jurisdiction. It is not a substitute for appeal and does not permit a re-evaluation of the evidence to arrive at a conclusion of innocence. The CA’s finding on the evidence was thus a reversible error. The proper remedy for the accused was a regular appeal, not certiorari. Consequently, the RTC decision, having been validly promulgated, must be reinstated in its entirety.