GR 173990; (October, 2009) (Digest)
G.R. No. 173990 ; October 27, 2009
EDGARDO V. ESTARIJA, Petitioner, vs. PEOPLE OF THE PHILIPPINES and EDWARD RANADA, Respondents.
FACTS
Petitioner Edgardo V. Estarija, then Harbor Master of the Philippine Ports Authority in Davao City, was charged with violating Section 3(b) of the Anti-Graft and Corrupt Practices Act ( Republic Act No. 3019 ). The Information alleged that on August 6, 1998, he requested and received Five Thousand Pesos (₱5,000.00) from the Davao Pilot Association in consideration for his issuance of berthing permits. After trial, the Regional Trial Court (RTC) of Davao City found him guilty beyond reasonable doubt and sentenced him to a straight penalty of seven years imprisonment.
Estarija appealed his conviction to the Court of Appeals. The appellate court affirmed the conviction but modified the penalty to an indeterminate sentence of six years and one month to nine years, with perpetual disqualification from public office. Unsatisfied, Estarija elevated the case to the Supreme Court via a Petition for Review under Rule 45, arguing that the RTC’s findings of guilt were erroneous.
ISSUE
Whether the Court of Appeals correctly exercised appellate jurisdiction over the RTC decision convicting Estarija.
RULING
The Supreme Court denied the petition, but not on the merits of the conviction. Instead, it resolved a fundamental jurisdictional error. The Court held that Estarija’s appeal to the Court of Appeals was fatally defective. Under Republic Act No. 8249 , which amended the jurisdiction of the Sandiganbayan, final judgments of the RTC in cases involving public officers with a salary grade below 27—like Estarija—must be appealed exclusively to the Sandiganbayan, not the Court of Appeals. Estarija’s disregard of this statutory rule meant he failed to perfect his appeal within the reglementary period.
Consequently, the RTC’s Decision dated March 15, 2000, became final and executory. The Court emphasized the doctrine of finality of judgment; a judgment that has attained finality becomes immutable and unalterable. It can no longer be modified, even if the penalty imposed by the RTC (a straight penalty) was technically erroneous under the Indeterminate Sentence Law. The correct penalty should have been indeterminate, but the Court could no longer correct it due to the judgment’s finality. Thus, the RTC Decision was declared final and executory.