GR L 55831; (May, 1983) (Digest)
G.R. No. L-55831 May 30, 1983
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GILBERT MEDRANO, ET AL., accused, ANTONIO POBLETE, MARCELO ARZADON and EDILBERTO ARZADON, defendants-appellants.
FACTS
This case originated from a criminal conviction. The trial court rendered a judgment of conviction against all accused, including Gilbert Medrano, Antonio Poblete, Marcelo Arzadon, and Edilberto Arzadon. Following the trial court’s decision, only three of the convicted individuals—Antonio Poblete, Marcelo Arzadon, and Edilberto Arzadon—perfected their appeal to the Supreme Court. Gilbert Medrano did not file any appeal and, consequently, accepted the trial court’s judgment against him.
In its decision dated May 31, 1982, the Supreme Court inadvertently included Gilbert Medrano among the appellants. This inclusion was a clerical error, as the records clearly showed that Medrano had not appealed. Medrano himself brought this error to the Court’s attention, complaining that he was wrongly treated as an appellant when he had not sought a review of his conviction.
ISSUE
Whether the Supreme Court had jurisdiction to review and modify the sentence imposed on Gilbert Medrano, who did not appeal his conviction.
RULING
The Supreme Court ruled that it lacked jurisdiction over Gilbert Medrano’s case. The legal principle is fundamental: an appellate court acquires jurisdiction over a case only upon the perfection of an appeal by the party adversely affected. Since Medrano did not appeal the trial court’s decision, the judgment against him became final and executory as to his person. The Supreme Court’s prior decision, which inadvertently included him as an appellant, was rendered without jurisdiction (coram non judice) concerning Medrano. A void judgment for lack of jurisdiction can be assailed at any time.
Therefore, the Court issued a Nonc Pro Tunc Resolution to correct the clerical error. The dispositive portion of its May 31, 1982 decision was amended to delete all references to Medrano as an appellant. The sentences for the actual appellants—Marcelo Arzadon, Edilberto Arzadon, and Antonio Poblete—were affirmed and modified as appropriate. Crucially, the sentence validly imposed by the trial court on Gilbert Medrano, which he had already begun serving, remained in full force and effect. The Court emphasized that its amended decision pertained only to the three appellants who properly invoked its appellate jurisdiction.