GR 134229; (November, 1999) (Digest)
G.R. No. 134229 November 26, 1999
LITO LIMPANGOG and JERRY LIMPANGOG, petitioners, vs. COURT OF APPEALS and PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioners Lito Limpangog and Jerry Limpangog were charged with Murder and two counts of Frustrated Murder before the Regional Trial Court (RTC) of Ormoc City, all arising from the same incident. In a Joint Decision dated September 15, 1994, the RTC found them guilty of all charges. For the Murder conviction, the court imposed the penalty of reclusion perpetua. For each Frustrated Murder conviction, it imposed an indeterminate prison term. The petitioners filed a single notice of appeal from this Joint Decision.
The Court of Appeals (CA) declared it had no jurisdiction over the appeal concerning the murder conviction because the penalty imposed was reclusion perpetua. Citing Supreme Court Circular No. 2-90, the CA dismissed the appeal for murder. However, it gave due course to the appeal for the two frustrated murder convictions, ultimately acquitting the petitioners of those charges. The petitioners then elevated the case to the Supreme Court, questioning the CA’s dismissal of their murder appeal.
ISSUE
Whether the Court of Appeals had jurisdiction over the petitioners’ appeal from the RTC’s Joint Decision which imposed reclusion perpetua for murder and lesser penalties for frustrated murder, all crimes arising from the same facts.
RULING
The Supreme Court ruled that the Court of Appeals had no jurisdiction. The appeal is null and void, and the case was ordered elevated to the Supreme Court for a complete review. The legal logic is anchored on the principle that an appeal of a single decision cannot be split between two courts. Under Article VIII, Section 5(2)(d) of the Constitution, the Supreme Court has exclusive appellate jurisdiction over criminal cases where the penalty imposed is reclusion perpetua or higher. Here, the RTC rendered a single Joint Decision for three interrelated crimes. Since one of the penalties imposed was reclusion perpetua, the entire decision falls under the Supreme Court’s exclusive appellate jurisdiction. The CA erred in dismissing the murder appeal and separately reviewing the frustrated murder convictions. This act of splitting the appeal is not permitted, as it disrupts the orderly administration of justice and risks conflicting dispositions. The proper procedure was for the CA to have forwarded the entire case record to the Supreme Court. Consequently, the Supreme Court set aside the CA Decision and ordered the elevation of the records for a de novo review of the RTC’s Joint Decision in its entirety.