GR 106531; (November, 1999) (Digest)
G.R. No. 106531 November 18, 1999
FERNANDO GARCIA, JUANITO GARCIA, and WENCESLAO TORRES, petitioners, vs. PEOPLE OF THE PHILIPPINES, and HON. RICARDO P. GALVEZ, in his official capacity as the Presiding Judge of Branch 29, Regional Trial Court of Iloilo, respondents.
FACTS
The petitioners were convicted of murder by the Regional Trial Court of Iloilo and each was sentenced to reclusion perpetua. They filed a motion for reconsideration, which the trial court denied. Upon receiving notice of the denial, petitioners did not file a notice of appeal. Consequently, the judgment became final, and the trial court issued warrants for their arrest.
Subsequently, petitioners filed a motion to lift the warrants and to allow an appeal, arguing that no appeal was necessary because a sentence of reclusion perpetua is subject to automatic review by the Supreme Court. The trial court denied this motion and a subsequent motion for reconsideration. Petitioners then filed this special civil action for mandamus to compel the trial court to forward the case records to the Supreme Court for the purported automatic review.
ISSUE
Whether a trial court’s decision convicting an accused of a capital offense and imposing the penalty of reclusion perpetua is subject to automatic review by the Supreme Court, thereby exempting the accused from the requirement of filing a notice of appeal.
RULING
The Supreme Court denied the petition for mandamus. The legal logic is clear and established: automatic review by the Supreme Court is mandated only when the penalty actually imposed by the trial court is death. This rule is based on the constitutional requirement for a review of all death penalty cases by the highest court. A sentence of reclusion perpetua, while a severe penalty, does not trigger this automatic review process.
Consequently, the ordinary rules of appeal apply. Since the petitioners did not file a notice of appeal within the reglementary period after their motion for reconsideration was denied, the trial court’s decision became final and executory. Mandamus, being a remedy to compel the performance of a ministerial duty, does not lie when there is no clear legal right to the performance of that duty. The trial court had no duty to forward the records because no automatic review was required, and no appeal was perfected. The Court affirmed its consistent jurisprudence on this distinction, thereby upholding the finality of the judgment against the petitioners.