G.R. No. L-40330 November 20, 1978
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. AMADO DANIEL alias “AMADO ATO”, accused-appellant.

FACTS

The case originated from the Court of First Instance of Baguio City, where Amado Daniel was accused of raping a 13-year-old girl on September 20, 1965, through force, intimidation, and the use of a sharp instrument, with the aggravating circumstance of dwelling. After trial, the court found him guilty and sentenced him to an indeterminate penalty ranging from six years and one day of prision mayor to twelve years and one day of reclusion temporal. Daniel appealed to the Court of Appeals.
The Court of Appeals, in its decision dated September 23, 1974, affirmed the trial court’s finding of guilt beyond reasonable doubt. However, it noted that the penalty imposed by the trial court was incorrect. Applying Republic Act No. 4111, which amended Article 335 of the Revised Penal Code effective June 20, 1964, the appellate court held that the proper penalty for simple rape was reclusion perpetua. Since the case involved a penalty now falling within the exclusive appellate jurisdiction of the Supreme Court, the Court of Appeals certified the entire case to the Supreme Court for appropriate proceedings, pursuant to the Judiciary Act.

ISSUE

The primary legal issue is whether the Supreme Court acquires jurisdiction over an appeal in a criminal case where the Court of Appeals, after finding the accused guilty, certifies the case because the proper penalty is reclusion perpetua or death, but its decision does not itself formally impose that penalty.

RULING

Yes, the Supreme Court acquires jurisdiction. The Court, speaking through Justice Muñoz Palma, resolved a preliminary question on appellate procedure. A minority view, expressed by Chief Justice Fred Ruiz Castro, held that for the Supreme Court to acquire jurisdiction, the Court of Appeals’ decision must have already imposed the penalty of reclusion perpetua or death in its dispositive portion. The majority, however, upheld the existing practice and the dispositive portion as rendered by the Court of Appeals.
The majority ruled that the certification by the Court of Appeals, accompanied by its comprehensive findings of fact and legal analysis concluding that the proper penalty is reclusion perpetua, is sufficient to vest jurisdiction in the Supreme Court. The Court traced this practice to the 1947 case of People v. Ramos, which required the Court of Appeals to make the necessary factual findings to support its opinion on the proper penalty when certifying a case. The law (the Judiciary Act) and the Rules of Court (Rule 124, Section 12) mandate certification when the appellate court is of the opinion that the penalty should be death or reclusion perpetua. The act of certification itself, based on that opinion, transfers jurisdiction. To require the Court of Appeals to enter a judgment imposing the penalty before certification would be a superfluity and could lead to procedural complications. Consequently, the Supreme Court assumed jurisdiction over the appeal to review the case and impose the correct penalty as warranted by the evidence and the law.