G.R. No. 248182. September 07, 2022.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. JOVENCIO ALLAN CIUDADANO Y SALCEDA, ACCUSED-APPELLANT.

FACTS

Accused-appellant Jovencio Allan Ciudadano was convicted by the Regional Trial Court (RTC) of Naga City for violation of Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) and was sentenced to life imprisonment and a fine. He appealed the conviction to the Court of Appeals (CA). The CA required the filing of an appellant’s brief. His counsel from the Public Attorney’s Office (PAO) filed three successive motions for extension of time to file the brief, citing heavy workload and other assigned tasks. The CA granted the first two motions but denied the third, dismissing the appeal for failure to file the brief within the reglementary period and deeming it abandoned.
Accused-appellant subsequently filed a motion to admit his attached brief and a motion for reconsideration. The CA denied these motions, ruling that the negligence of counsel binds the client. The CA emphasized that the explanations for the delay were unsubstantiated and that counsel had failed to establish an efficient system to monitor court deadlines. The case was elevated to the Supreme Court via appeal.

ISSUE

Whether the Court of Appeals gravely abused its discretion in dismissing accused-appellant’s appeal for failure to file the appellant’s brief on time.

RULING

The Supreme Court granted the appeal and set aside the CA’s resolutions. The Court ruled that the dismissal constituted a grave abuse of discretion. While the right to appeal in criminal cases where the penalty is reclusion perpetua or higher is a statutory right, procedural rules should be liberally construed to serve substantial justice, especially when life or liberty is at stake. The Court found that the CA’s outright dismissal was too severe a penalty for the procedural lapse.
The legal logic hinges on the principle that appeals involving life imprisonment demand the utmost scrutiny. The Court distinguished this from cases where dismissal for procedural delays is warranted, noting that the delay here was not inordinate or vexatious. The PAO counsel’s failure, while negligent, should not deprive the accused of a review of a conviction carrying a life sentence. The Court emphasized that the power to dismiss an appeal is discretionary and must be exercised judiciously, with a paramount regard for the constitutional right to due process and the need to avoid a miscarriage of justice. The case was remanded to the CA to give due course to the appeal and resolve it on its merits, particularly noting the accused-appellant’s substantive arguments regarding alleged breaks in the chain of custody of the seized drugs.