G.R. No. L-45798 December 15, 1982
VENANCIO VILLANUEVA, petitioner, vs. COURT OF FIRST INSTANCE OF ORIENTAL MINDORO, PINAMALAYAN, BRANCH II, and THE PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioner Venancio Villanueva was convicted of murder for a crime committed on February 22, 1974, when he was 19 years, 11 months, and 22 days old. The Court of First Instance promulgated its decision on July 30, 1975, sentencing him to reclusion perpetua. Villanueva did not appeal and began serving his sentence. However, on September 25, 1975, he filed an urgent motion invoking the benefits of Presidential Decree No. 603 (The Child and Youth Welfare Code), which took effect on June 10, 1975. He argued that as a youthful offender under 21 at the time of the crime, the court should have suspended his sentence and committed him to the custody of social welfare authorities instead of imposing a penalty.
The trial court initially granted his motion in a resolution dated December 17, 1975, declaring its earlier promulgation null and void for having been made after P.D. No. 603’s effectivity and ordering his transfer to a rehabilitation center. However, the court later issued orders on December 4, 1976, and February 4, 1977, which effectively reinstated the original judgment of conviction. Villanueva challenged these orders, contending they were issued without or in excess of jurisdiction.

ISSUE

Whether the trial court’s orders dated December 4, 1976, and February 4, 1977, which upheld the original conviction, are valid despite the petitioner’s claim for benefits under P.D. No. 603.

RULING

The Supreme Court upheld the validity of the assailed orders and dismissed the petition. The legal logic is clear: first, under Article 192 of P.D. No. 603, the suspension of sentence and commitment to the custody of social welfare authorities apply only if the offender is under twenty-one years of age at the time of judgment. While Villanueva was a youthful offender (under 21) when he committed the crime on February 22, 1974, he was already over twenty-one years old when the judgment was promulgated on July 30, 1975. Consequently, he was no longer entitled to the benefits of suspension of sentence under the decree.
Second, the judgment of conviction rendered on July 30, 1975, was valid and final. The trial court had jurisdiction over the case and the person of the accused. Any error in failing to apply P.D. No. 603, assuming it was applicable, would merely render the judgment erroneous but not void. A judgment rendered by a court with jurisdiction remains valid and becomes final if not appealed. Villanueva’s failure to appeal and his commencement of service solidified the judgment’s finality. His subsequent motion, filed almost two months after promulgation, was thus untimely and could not revive or nullify a final judgment. Therefore, the trial court’s initial resolution of December 17, 1975, granting the motion, was itself issued without jurisdiction. The later orders of December 4, 1976, and February 4, 1977, which correctly upheld the final and executory judgment, were valid.