THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TIMOTEO TAMAYO, defendant-appellant.
FACTS
Timoteo Tamayo pleaded guilty to illegal possession of a firearm and ammunition. The trial court, considering the plea and the fiscal’s recommendation, initially sentenced him to pay a fine. Almost seven months later, upon the Provincial Fiscal’s motion for reconsideration (filed within 15 days of the original judgment but decided much later), the court amended its decision to impose a heavier penalty of imprisonment under Republic Act No. 4, which it had initially overlooked. Tamayo appealed, arguing the trial court no longer had jurisdiction to modify its judgment.
ISSUE
Whether the trial court had jurisdiction to modify its judgment of conviction nearly seven months after its promulgation, despite the fiscal’s motion for reconsideration being filed within 15 days.
RULING
No. Under Section 7, Rule 116 of the Rules of Court, a judgment of conviction may be modified only before it becomes final. A judgment becomes final after the lapse of the 15-day period for perfecting an appeal, unless that period is interrupted by a motion for new trial filed by the defendant under Section 1, Rule 117. A motion for reconsideration by the prosecution does not interrupt or extend this 15-day period. Since the court’s amended decision was rendered long after the 15-day period had lapsed, it was issued without jurisdiction and is null and void. The Court set aside the amended judgment and declared the original judgment final, without prejudice to any recourse the accused may have against it.
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