Rule 124

People v. Mateo, G.R. Nos. 147678-87, 7 July 2004

Facts:
Appellant Efren Mateo faced ten charges of rape, allegedly committed on different dates. The
accusations were uniformly presented in ten informations filed in the Regional Trial Court of
Tarlac. The complainant, Imelda Mateo, stated that the rapes occurred in their house in
Buenavista, Tarlac, during the absence of her mother, Rosemarie Capulong, who was the
guardian of the complainant. Imelda claimed that the incidents took place on various dates
when her mother was either away for work, seminars, or other reasons. The complainant
initially asserted a consistent pattern in the incidents, including appellant covering her mouth
with a handkerchief to prevent her from shouting. However, she later changed her testimony on
this detail.

Issue:
The primary issue revolved around the credibility of the complainant's testimony and the
consistency of her statements regarding the alleged rapes. Discrepancies were noted in Imelda's
accounts, including variations in the presence of her siblings during the incidents and
inconsistencies in whether her mouth was covered during the assaults.

Ruling:
The trial court found appellant guilty of ten counts of rape and sentenced him to suffer
reclusion perpetua for each count.The Supreme Court, after a thorough review, identified
significant inconsistencies and contradictions in the complainant's testimony, raising doubts
about the veracity of her claims.The Court highlighted discrepancies in Imelda's statements
regarding the presence of her siblings during the incidents, the use of a handkerchief to cover
her mouth, and the whereabouts of her mother on certain dates.Given the doubt cast on the
complainant's credibility and the serious nature of the charges, the Supreme Court remanded
the case to the Court of Appeals for an intermediate review before final disposition. The ruling
emphasized the importance of ensuring the correctness of judgments, especially in cases
involving severe penalties, and justified the procedural adjustment based on the Supreme
Court's rule-making authority.

Celestial v. People, G.R. No. 214865, 19 August 2015

Facts

Rosvee Celestial, former "Accounting-in-Charge" of Glory Philippines, was terminated in 2006

for making anomalous withdrawals from the company's dollar account. Glory Philippines filed a
criminal complaint, leading to six counts of qualified theft charges. The Regional Trial Court
(RTC) convicted Celestial, sentencing her to 20 years of Reclusion Temporal for each count.

The CA directed Celestial to file an appellant's brief, but her counsel failed to do so despite
extensions. The CA, citing Rule 124 of the Revised Rules on Criminal Procedure, considered the
appeal abandoned and dismissed it.
Issue

Whether the CA erred in dismissing the case due to the petitioner's failure to file the appellant's
brief.

Ruling

The CA's dismissal was in order. Section 8, Rule 124 grants the CA discretion to dismiss an
appeal if the appellant fails to file the brief. The petitioner's claim of lack of notice was
dismissed, as notice to counsel is notice to the client. The negligence of the counsel, Atty.
Paredes, bound the petitioner. The CA found both the counsel and the petitioner negligent,
justifying the dismissal. The petition was denied, and the CA's decision was affirmed with the
modification of the penalties imposed by the RTC. The total imprisonment period was limited to
40 years for six counts of qualified theft through falsification of commercial documents.

Ola v. People, G.R. No. 195547, 2 December 2015

FACTS:
The case involves a petition for review on certiorari filed by Ma. Corazon M. Ola against the
Court of Appeals (CA) Resolutions dated September 9, 2010, December 14, 2010, and February
14, 2011, in CA-GR. CR No. 32066. Ola, along with co-accused Manuel Hurtada and Aida Ricarse,
faced charges of estafa under Article 315, paragraph 2 of the Revised Penal Code. The case
originated from an Information filed with the Regional Trial Court (RTC) of Las Piñas City, alleging
that they defrauded Elizabeth T. Lauzon by falsely representing their authority to sell a parcel of
land. After trial, the RTC found the accused guilty of estafa, and each was sentenced to
imprisonment and ordered to indemnify Lauzon.Ola and her co-accused appealed the RTC
decision to the CA.

ISSUE:
Whether the denial by the Court of Appeals of Ola's motion to amend her appeal brief is a final
order or an interlocutory order.

RULING:
The Court held that the denial of Ola's motion to amend her appeal brief is an interlocutory
order, as it does not dispose of the case completely. Therefore, the proper remedy for an
interlocutory order is a petition for certiorari under Rule 65, not a petition for review on
certiorari under Rule 45. Since Ola's petition was erroneously filed under Rule 45, the Court
dismissed the petition. The Court also rejected Ola's argument that the denial violated her right
to due process, emphasizing that interlocutory orders need not express facts and law. The CA's
application of Section 4, paragraph 2, Rule 124 of the Rules of Court, and refusal to grant Ola's
motion to amend were deemed correct, considering the substantial delay in filing the motion.
The Court affirmed the CA Resolutions and directed the CA to proceed with the resolution of
the case on the merits with dispatch.
Villamor v. People, G.R. No. 172110 and 181804, 1 August 2011

FACTS:
Minda Villamor and Glicerio Vios, Jr., along with other co-accused, were charged with frustrated
murder for attacking and stabbing Jean V. Jumawan. The incident occurred on January 7, 1999,
at Iligan City East Central School. Ricardo Tormis, one of the accused, stabbed the victim
multiple times, causing severe injuries. The prosecution presented evidence, including witness
testimonies and medical certificates, to establish the guilt of the accused.

Accused Nicolas Caballero, initially charged, became a state witness after providing information
on the planning and execution of the crime. He implicated Vios and Villamor in planning the
attack.

The Regional Trial Court (RTC) convicted Vios and Villamor of frustrated murder. The Court of
Appeals (CA) affirmed the decision, but with modifications in the damages awarded.

ISSUE:
Whether the Court of Appeals erred in affirming the RTC's decision convicting Minda Villamor
and Glicerio Vios, Jr. of frustrated murder.

RULING:
The petitions were denied, and the CA decision was affirmed. The Court emphasized strict
compliance with procedural rules and dismissed Glicerio Vios, Jr.'s appeal due to the late filing
of the appellant's brief. Minda Villamor's petition was also denied as her motion for extension
of time to file a motion for reconsideration was not allowed, rendering the CA decision final and
executory. The Court cited Rule 124, Section 8, which allows the Court of Appeals to dismiss an
appeal if the appellant fails to file the brief within the prescribed time. The decision underscores
the mandatory nature of procedural rules and the importance of strict compliance to ensure the
orderly and speedy conduct of judicial business.

Navarro v. Court of Appeals, G.R. Nos. 112389-90, 1 August 1994

Facts:
Mercedes D. Navarro was convicted of violating B.P. 22 (Bouncing Checks Law) in Criminal Cases
Nos. L-3848 and L-3849 in the Regional Trial Court of Pangasinan.Navarro's appeal to the Court
of Appeals was dismissed for failure to file her appellant's brief. After the dismissal, she filed a
motion for new trial on the ground of "newly-discovered evidence," specifically an alleged
payment to Tamayo's saleslady.

Issue:
Whether Navarro's motion for new trial was properly denied by the Court of Appeals.
Ruling:
Yes. The Court of Appeals correctly denied Navarro's motion for new trial. The dismissal of her
appeal became final after the lapse of 15 days from the service of a copy thereof upon her, and
the motion for new trial was filed after the dismissal.
Rule 124, Sec. 14, of the Rules of Court allows a motion for new trial after the appeal has been
perfected and before the judgment becomes final. However, Navarro's motion for new trial was
filed after the finality of the appellate court's resolution dismissing her appeal.
The alleged "newly-discovered evidence" was not substantial and, even if admitted, would not
have reversed Navarro's conviction. The supposed payment, if true, did not have a specific date
and lacked credibility. The Court of Appeals did not err in denying the motion for new trial.
The conviction was upheld as Navarro failed to prove payment within the required period after
notice of dishonor, and the alleged evidence would not have altered the judgment.

People v. Mirandilla, Jr., G.R. No. 186417, 27 July 2011

FACTS:
On December 2, 2000, during a fiesta in Barangay San Francisco, Legazpi City, the victim (AAA)
was dancing with her elder sister, BBB. AAA went out to buy candies and was abducted by the
accused, Felipe Mirandilla, Jr., who threatened her with a knife. AAA was taken to various
locations, raped multiple times, and detained for 39 days. AAA managed to escape, sought help,
and identified Mirandilla as the perpetrator.

ISSUE:
Whether the prosecution witness (AAA) is credible.

RULING:
The trial court found AAA credible, stating that her testimony was consistent, steady, and firm.
The court also noted the absence of ill motives to fabricate charges.The Court of Appeals
affirmed AAA's credibility, and the Supreme Court deferred to the lower courts' assessment.
The defense's "sweetheart theory" was not proven, as it lacked credible evidence to support the
claim of a consensual relationship. Rule 124 pertains to appeals from judgments or final orders
of the RTC to the Court of Appeals. The case involves an appeal from the RTC to the CA, which is
in accordance with Rule 124. The Supreme Court, in its ruling, exercised its authority to review
the entire case, including questions not raised by the parties, as allowed by Rule 124, Section
11. The Court modified the CA Decision, finding Mirandilla guilty of the special complex crime of
kidnapping and serious illegal detention with rape, consistent with the RTC's ruling.

People v. Fitzgerald, G.R. No. 149723, 27 October 2006

Facts:
Victor Keith Fitzgerald, an Australian citizen, was charged with Violation of Art. III, Section 5,
paragraph (a), subparagraph (5) of Republic Act (R.A.) No. 7610. The accusation involved
inducing a minor, "AAA," 13 years of age, to engage in prostitution through the use of laced
drugs and other inducements.
Issue:
Whether the Court of Appeals erred in granting bail to Victor Keith Fitzgerald despite being
charged with a crime punishable by reclusion perpetua and strong evidence of guilt.
Ruling:
Yes. Fitzgerald was initially convicted by the Regional Trial Court (RTC) but was granted a new
trial by the Court of Appeals (CA). The CA retained appellate jurisdiction over the case and
delegated to the RTC the function of receiving newly-discovered evidence. The CA issued a
Resolution on August 31, 2001, granting Fitzgerald bail primarily due to his old age and poor
health. The CA, in doing so, ignored the strong evidence of guilt and granted bail based on
grounds not stated in Fitzgerald's Motion for Bail. The RTC, in its previous order, noted a
potential risk of Fitzgerald committing a similar offense if released on bail. The CA's decision to
grant bail on the mere claim of illness without specific findings about the severity of the
condition and the potential risk of reoffending was erroneous. Bail is not granted on the basis of
health alone, and the CA disregarded the substantive and procedural requirements for bail,
including the existence of strong evidence of guilt and the risk of flight or committing another
crime.The CA's decision to grant bail is set aside, and an order of arrest is issued against Victor
Keith Fitzgerald.

People v. Bitanga, G.R. No. 159222, 26 June 2007

FACTS:
Rafael Bitanga was charged with estafa based on a complaint by Traders Royal Bank (TRB).
Bitanga pleaded "not guilty" and was allowed to post bail. During the trial, TRB presented
witnesses detailing how Bitanga deceived the bank with foreign checks. When it was time for
Bitanga to present his case, he and his counsel failed to appear, and a warrant of arrest was
issued.
In absentia, the RTC rendered a decision on February 29, 2000, finding Bitanga guilty of estafa,
sentencing him to imprisonment, and ordering indemnification to TRB.

ISSUE:
Whether the Court of Appeals erred in granting the Petition for Annulment of Judgment filed by
Bitanga.

RULING:
The petition is granted, annulling the decision of the Court of Appeals. The CA's decision to
grant annulment based on extrinsic fraud is erroneous. The Court clarified that Bitanga's remedy
of annulment was not applicable to criminal cases, citing Section 18, Rule 124. The Court
rejected the claim of extrinsic fraud, asserting that Bitanga's negligence, particularly jumping
bail, led to the failure to present a defense.The decision emphasizes the exceptional nature of
annulment, requiring the absence of alternative remedies and the presence of jurisdictional issues
or extrinsic fraud.

Rule 125
People v. Mateo, G.R. Nos. 147678-87, 7 July 2004
Facts:
On October 30, 1996, appellant Efren Mateo was charged with ten counts of rape allegedly
committed on various dates in 1995 and 1996 against his stepdaughter Imelda Mateo. The trial
proceeded, and Imelda recounted the incidents, claiming they all followed a similar pattern:
committed inside their house in Buenavista, Tarlac, during the night, with her attempts to resist
being futile.

Issue:
Whether the guilt of the appellant, Efren Mateo, has been proven beyond reasonable doubt for
the ten counts of rape.

Ruling:
No, the guilt of the appellant has not been proven beyond reasonable doubt. The court, in a
decision dated January 23, 2001, found Efren Mateo guilty of ten counts of rape and sentenced
him to reclusion perpetua for each count. However, the Supreme Court, after a thorough
review, has identified inconsistencies and discrepancies in Imelda's testimony that cast doubt on
the credibility of her allegations. Rule 125, which deals with the rules of procedure in criminal
cases, particularly the evaluation of evidence, requires that guilt must be proven beyond
reasonable doubt. The Supreme Court, in this case, emphasizes the need for convincing and
straightforward testimony, especially in cases relying heavily on the victim's account.