G.R. No. 251830, June 28, 2021
Imelda G. Rodriguez, Petitioner, vs. Government of the United States of America, represented by the Philippine Department of Justice, Respondent.

FACTS

In 2001, the Government of the United States of America (respondent), represented by the Philippine Department of Justice, filed a Petition for Extradition against spouses Eduardo Tolentino Rodriguez and Imelda G. Rodriguez (petitioner) before the Regional Trial Court (RTC) of Manila. The petition sought their extradition to face trial in California for offenses including Presenting Fraudulent Claims, Grand Theft of Personal Property, Attempted Grand Theft, and, for petitioner specifically, Bribery. The alleged crimes involved fraudulently collecting insurance proceeds by falsely reporting deaths. Eduardo later voluntarily submitted to extradition in 2003, leaving petitioner as the sole respondent. Throughout the protracted proceedings from 2001 to 2017, petitioner repeatedly failed to file an Answer to the petition despite multiple orders from the RTC directing her to do so. Instead, she filed various motions addressing procedural issues, requests for deferment, and motions for inhibition. On June 15, 2017, the RTC, noting petitioner’s continued failure to file a responsive pleading despite prior orders, effectively declared her in default and allowed respondent to present evidence ex-parte. Petitioner’s subsequent motions, including a motion to set aside the order of default, were denied by the RTC. After respondent presented its evidence, the RTC granted the petition for extradition in a Decision dated April 19, 2018. Petitioner filed a Petition for Certiorari with the Court of Appeals (CA) challenging the default orders and also appealed the RTC’s decision granting extradition. The CA consolidated these cases.

ISSUE

The primary issue is whether the Court of Appeals erred in dismissing petitioner’s Petition for Certiorari (which assailed the RTC orders declaring her in default and denying relief therefrom) and in denying her appeal of the RTC decision granting the petition for extradition.

RULING

The Supreme Court denied the petition and affirmed the assailed CA Decision and Resolution. The Court held that the RTC did not commit grave abuse of discretion in declaring petitioner in default. Her failure to file an Answer for 16 years despite repeated directives constituted a waiver of her right to present evidence and participate in the trial, warranting a default declaration under Section 3, Rule 9 of the Rules of Court. The Court found no merit in petitioner’s claim of denial of due process, as she was given ample opportunity to be heard through the numerous motions she filed, and the essence of due process in extradition proceedings is simply the opportunity to be heard. Furthermore, the Court ruled that petitioner’s Petition for Certiorari before the CA was correctly dismissed as it was rendered moot and academic by her filing of an ordinary appeal of the RTC’s final judgment on the merits; the issues raised in the certiorari petition were deemed integrated into the appeal. On the merits of the extradition case, the Court found that the RTC and CA correctly granted the petition, as respondent had sufficiently established the existence of an extradition treaty, the extraditable character of the offenses, the criminal charges against petitioner in the requesting state, and her identity. Petitioner’s defenses, raised belatedly, were deemed waived due to her default.