People v. Val de Los Reyes

People v.
de los Reyes
G.R. Nos. 139331 & 140845-46 | October 16, 2012
Perlas-Bernabe, J.:
Nature:
Appeal from a decision of the RTC
Facts:
1. December 22, 1994, at around 4pm, Imelda Brutas, upon the request of her sister
Clara, went to the house of de los Reyes to bring some pictures
2. Upon arrival thereat, Imelda saw de los Reyes outside his house talking to another
man, whom de los Reyes introduced as Val de los Reyes (herein Val)
3. Because it suddenly rained, the 3 of them took shelter inside de los Reyes’ house
4. De los Reyes and Val forced Imelda to drink 2 bottles of beer, causing her to feel
dizzy
a. It was under this condition that Val succeeded in having sexual intercourse
with her against her will
b. Thereafter, de los Reyes took his turn with Imelda, aided by Val who covered
her mouth and held her hands
5. Not satisfied, Bal once again ravished Imelda, with the assistance of de los Reyes
who likewise covered her mouth and held her hands
6. Imelda filed criminal complaints for rape against de los Reyes and Val
7. Unfortunately, the authorities were able to arrest only appellant while Val remained at
large
a. Thus de los Reyes was arraigned and pleaded not guilty
b. Before prosecution could conclude the presentation of its evidence, he jumped
bail
i. Thus he was tried in absentia
8. RTC
a. Convicted de los Reyes of 2 counts of rape and sentenced to suffer the death
penalty
9. In view of the penalty of death
a. Case was elevated to the Court on automatic review
10. Subsequently, RTC revived the criminal cases against Val, who, after trial, was
likewise found guilty beyond reasonable doubt of 3 charges of rape
11. The Court later ordered the consolidation of the 5 cases
12. The Court en banc rendered a decision vacating the judgment of conviction against
Val
a. finding that the RTC violated Secs. 1 and 2, Rule 132 and Sec. 1, Rule 133 of
the ROC
i. it would appear from the records that during Val’s trial, the
prosecution merely adopted the transcript of the stenographic notes
during the trial against de los Reyes and asked the prosecution
witnesses to affirm their previous testimonies
b. thus, the Court remanded the cases to RTC for rehearing
c. meanwhile, the automatic review of the cases against de los Reyes was held in
abeyance
13. Val was tried anew before the RTC
14. RTC
a. Convicted him for 3 counts of rape and sentenced him to suffer the death
penalty
15. CA
a. Affirmed conviction of Val
b. Reduced the penalty of death to reclusion perpetua
Issue:
WON it is necessary to transfer these cases to the CA for immediate review
Held:
NO. The Supreme Court dismissed the appeal
1. At the outset, the Court notes that these cases were elevated to Us on
automatic review in view of the RTC’s imposition of the death penalty
upon appellant in its June 25, 1997 Decision. However, with the Court’s
pronouncement in the 2004 case of People v. Mateo, 433 SCRA 640
[2004], providing for and making mandatory the intermediate review by
the CA of cases involving the death penalty, reclusion perpetua or life
imprisonment, the propercourse of action would be to remand these cases
to the appellate court for the conduct of an intermediate review.
2. Records reveal that the appellant jumped bail during the proceedings
before the RTC and was, in fact, tried and convicted in absentia. There is
dearth of evidence showing that he has since surrendered to the court’s
jurisdiction. Thus, he has no right to pray for affirmative relief before the
courts. Once an accused escapes from prison or confinement, jumps bail
as in appellant’s case, or flees to a foreign country, he loses his standing
in court, and unless he surrenders or submits to the jurisdiction of the
court, he is deemed to have waived any right to seek relief therefrom.
a. Thus, even if the Court were to remand these cases to the CA
for intermediate review, the CA would only be constrained to
dismiss appellant’s appeal, as he is considered a fugitive from
justice. On this score, Section 8, Rule 124 of the Rules of
Court is relevant, which provides: SEC. 8. Dismissal of appeal for
abandonment or failure to prosecute.—The Court of Appeals may,
upon motion of the appellee or motu proprio and with notice to the
appellant in either case, dismiss the appeal if the appellant fails to
file his brief within the time prescribed by this Rule, except where
the appellant is represented by a counsel de officio. The Court of
Appeals may also, upon motion of the appellee or motu proprio,
dismiss the appeal if the appellant escapes from prison or
confinement, jumps bail or flees to a foreign country during the
pendency of the appeal
3. It bears to stress that the right to appeal is merely a statutory privilege,
and, as such, may be exercised only in the manner and in accordance
with the provisions of the law. The party who seeks to avail of the same
must comply with the requirements of the Rules, failing which, the right to
appeal is lost.

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