G.R. No. 175602 ; February 13, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. PO2 EDUARDO VALDEZ and EDWIN VALDEZ, Accused-Appellants.

FACTS

Accused-appellants PO2 Eduardo Valdez and Edwin Valdez were convicted by the Regional Trial Court for three counts of murder and sentenced to reclusion perpetua for each count. The Court of Appeals affirmed the conviction with modifications to the damages. Edwin Valdez subsequently filed a motion to withdraw his appeal, which the Supreme Court granted, rendering his conviction final and executory. Eduardo Valdez continued his appeal.
The Supreme Court, in a Judgment promulgated on January 18, 2012, modified Eduardo’s conviction. It found that the qualifying circumstance of treachery was not sufficiently proven. The killing was downgraded from Murder to Homicide for each count. Eduardo was sentenced to an indeterminate penalty of 10 years of prision mayor as minimum to 17 years of reclusion temporal as maximum for each count of Homicide.

ISSUE

Whether the favorable judgment modifying the conviction of Eduardo Valdez from Murder to Homicide can be applied to his co-accused, Edwin Valdez, whose conviction for Murder had already become final and executory.

RULING

Yes. The Supreme Court granted Edwin Valdez’s plea for the application of the favorable judgment. The legal logic is anchored on Section 11(a), Rule 122 of the Rules of Court, which states that an appeal taken by one or more of several accused shall not affect those who did not appeal, except insofar as the judgment of the appellate court is favorable and applicable to the latter. This rule is grounded in equity and justice, ensuring that similarly situated accused receive equal treatment under the law.
The Court emphasized that the January 18, 2012 judgment was favorable to Edwin as it reduced the crime and prescribed a lighter, indeterminate penalty, making him eligible for parole, unlike the indivisible penalty of reclusion perpetua. The factual and legal basis for the modification—the absence of treachery—applied equally to both accused, as they were convicted as principals for the same acts. Jurisprudence consistently holds that a favorable ruling for one accused, even if based on a re-evaluation of facts common to all, should benefit a co-accused whose conviction is final, provided the judgment is intrinsically favorable. The Solicitor General interposed no opposition, finding the plea in accord with law. Thus, Edwin Valdez is entitled to the same modified conviction and penalties as his brother.