GR 170565; (January, 2006) (Digest)
G.R. No. 170565, January 31, 2006
People of the Philippines, Appellee, vs. Isidro Flores y Lagua, Appellant.
FACTS
Accused Isidro Flores was charged with 181 counts of rape against his minor ward. The Regional Trial Court of Makati found him guilty as charged and imposed the death penalty for each count. Following the procedure established in People v. Mateo, the records were transmitted to the Court of Appeals for an intermediate review. However, the Court of Appeals dismissed the appeal, declaring it abandoned due to the accused’s failure to file his appellant’s brief despite notice. The appellate court then elevated the records to the Supreme Court for automatic review.
ISSUE
Whether the Court of Appeals erred in dismissing the accused’s appeal for failure to file his appellant’s brief in a case where the death penalty was imposed.
RULING
Yes. The Court of Appeals committed a serious, reversible error. In criminal cases where the penalty imposed is reclusion perpetua, life imprisonment, or death, an appeal is a matter of right, not discretion. The review of a death penalty judgment is automatic and mandatory. This rule, rooted in constitutional and statutory safeguards for the protection of the accused, is designed to ensure the utmost circumspection when a person’s life is at stake.
The Supreme Court emphasized that this automatic review cannot be waived by the accused or evaded by the courts. It is a positive legal requirement that brooks no interference. The rationale, as established in early jurisprudence, is to provide a “second chance for life” by mandating the highest tribunal’s scrutiny of the facts and the legality of the sentence. The Rules of Court, specifically Rule 122, Sections 3(d) and 10, explicitly provide for the automatic review by the Court of Appeals in death penalty cases, irrespective of the accused’s actions in pursuing the appeal. Therefore, the appellate court’s dismissal of the appeal based on procedural default was fundamentally incorrect. The Supreme Court set aside the Court of Appeals’ resolution and remanded the case for the mandatory review and appropriate disposition.