GR 173654; (July, 2009) (Digest)
G.R. No. 173654 -765; July 30, 2009
PEOPLE OF THE PHILIPPINES, Plaintiff-appellee, vs. TERESITA PUIG and ROMEO PORRAS, Accused-Appellants.
FACTS
This case involves a series of criminal cases (No. 05-3054 to 05-3165) against accused-appellants Teresita Puig and Romeo Porras. In a Decision dated August 28, 2008, the Supreme Court granted the People’s petition for review on certiorari, reversing and setting aside the Regional Trial Court (RTC) orders that had dismissed the criminal cases. The dispositive portion of that Decision directed the issuance of warrants of arrest against both Puig and Porras and ordered the RTC to proceed with trial.
Subsequently, on September 2, 2008, the Supreme Court En Banc issued a Warrant of Arrest. However, this warrant was addressed only to Teresita Puig, commanding her arrest and commitment to the Correctional Institution for Women. The warrant made no mention of Romeo Porras. The present Resolution was issued to address this discrepancy and clarify the proper procedural step following the Court’s August 28, 2008 Decision.
ISSUE
Whether the Warrant of Arrest dated September 2, 2008, which ordered only the arrest and commitment of accused Teresita Puig, conforms to the Court’s prior Decision and the applicable legal procedure at that stage of the proceedings.
RULING
The Supreme Court ruled that the September 2, 2008 Warrant of Arrest was improper and must be recalled. The legal logic is anchored on the purpose and stage of the proceedings. The Court’s August 28, 2008 Decision explicitly ordered the reversal of the dismissal and the issuance of warrants against both respondents, Teresita Puig and Romeo Porras, for the purpose of proceeding to trial. At this juncture, the cases were being reinstated for trial on the merits; no judgment of conviction had been rendered.
Consequently, the order for Puig’s commitment to a penal institution was premature and legally erroneous. Commitment to a correctional facility is a consequence of a final judgment of conviction, not a pre-trial measure. The only proper procedural order at this stage is the issuance of warrants for the arrest of both accused to secure their presence at trial, as originally decreed. Therefore, the Court recalled the previous warrant and issued a new one commanding the arrest of both Puig and Porras specifically for the purpose of further proceedings and trial on the merits, without any directive for immediate commitment. This ensures the accused are brought under the court’s jurisdiction while preserving their constitutional right to be presumed innocent until proven guilty.