GR 125550; (July, 2000) (Digest)
G.R. No. 125550; July 11, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LUDIGARIO CANDELARIO and GERRY LEGARDA, accused-appellants.
FACTS
This case involves a post-conviction resolution concerning accused-appellant Gerry Legarda. The Supreme Court previously affirmed with modification the trial court’s decision convicting Legarda and his co-accused of Robbery with Multiple Rape. Legarda, sentenced to reclusion perpetua, was determined to be a youthful offender at the time of the crime’s commission. Consequently, he was committed to the custody of the Department of Social Welfare and Development (DSWD) at the Regional Rehabilitation Center for Youth pursuant to Article 192 of the Child and Youth Welfare Code (PD 603). After the judgment became final and executory, the DSWD Field Office VI submitted a Final Report recommending Legarda’s discharge. The report detailed his exemplary conduct, active participation in rehabilitation programs, academic achievements, and the expressed willingness and capability of his father to assume custody.
ISSUE
Whether the Supreme Court can directly order the release of youthful offender Gerry Legarda based solely on the favorable recommendation of the DSWD.
RULING
No. The Supreme Court cannot directly order the release. The legal logic is anchored on the specific procedural framework established by Presidential Decree No. 603 for the discharge of youthful offenders. Article 196 of PD 603 explicitly provides that the dismissal of the case and the final discharge of a youthful offender, upon a showing of proper behavior and capability to be a useful member of the community, must be done by the court that ordered the suspension of the sentence. This requires a judicial review of the DSWD’s recommendation by the trial court. The Supreme Court, in this resolution, cited its precedent in People vs. Ricky Galit, which clarified that the DSWD’s recommendation alone is insufficient for release. The trial court must conduct its own review, seeking concrete facts to confirm the offender’s reformation and readiness to rejoin society. This process is not a new criminal trial but a limited inquiry into the offender’s rehabilitation. Therefore, the Supreme Court remanded the DSWD’s Final Report to the Regional Trial Court of Roxas City, Branch 14, for appropriate review and judgment, without prejudice to Legarda’s civil liabilities.