The Supreme Court affirmed that a defendant who escapes from custody forfeits their right to appeal a conviction. By fleeing, the accused demonstrates a contempt for the law, waiving the right to seek relief from the court unless they surrender or are rearrested within a specific timeframe. This ruling highlights the critical importance of adhering to legal processes and respecting the jurisdiction of the courts.
From Jailbreak to Legal Dead End: Can a Fugitive Pursue an Appeal?
Francisco Taruc was convicted of murder by the Regional Trial Court (RTC) of Bataan and sentenced to death. However, before the Court of Appeals could review his case, Taruc escaped from prison. The central legal question became whether an escaped convict, by evading the legal process, retains the right to appeal their conviction. This issue highlights the intersection of an individual’s right to appeal and their responsibility to comply with the legal system.
The Supreme Court addressed this issue by referencing Rule 120, Section 6 of the Revised Rules of Criminal Procedure, which states that if an accused fails to appear at the promulgation of judgment without justifiable cause, “he shall lose the remedies available in these Rules against the judgment and the court shall order his arrest.” The rule allows for a 15-day window for surrender and a motion for leave of court to avail of remedies, provided the absence was justifiable. Taruc did not surrender within this timeframe.
Building on this, the Court also cited Rule 124, Section 8, paragraph 2, which pertains to the Court of Appeals and allows for the dismissal of an appeal if “the appellant escapes from prison or confinement, jumps bail or flees to a foreign country during the pendency of the appeal.” This provision reinforces the principle that an appellant cannot benefit from the legal system while simultaneously evading it. While this rule specifically applies to the Court of Appeals, Rule 125, Section 1 extends this to the Supreme Court, establishing uniform procedure.
The Court emphasized that Taruc’s escape constituted an implied waiver of his right to appeal. The Court explained in People v. Ang Gioc, “When the accused flees after the case has been submitted to the court for decision, he will be deemed to have waived his right to appeal from the judgment rendered against him x x x.” This precedent establishes that the right to appeal, while fundamental, can be forfeited by the appellant’s actions.
It’s important to note that the Court of Appeals initially took cognizance of the case because of the original death penalty imposed by the trial court, recognizing that automatic review is mandatory in such cases, representing not just a power, but the duty to review. Despite this review, the Supreme Court clarified that Taruc’s escape still implied a waiver of his right to appeal further.
The implications of this decision are significant. Individuals who attempt to evade the legal system by escaping custody risk forfeiting their right to appeal, effectively losing their opportunity to challenge their convictions in higher courts. This underscores the principle that the right to seek legal redress is contingent upon respecting and complying with the judicial process. The court stated it plainly in People v. Mapalao: “[O]nce an accused escapes from prison or confinement or jumps bail 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 from the court.”
By putting himself beyond the reach of the legal process, Taruc showed contempt for the law, preventing any leniency from the appellate court, the Supreme Court explained. The decision reaffirms that the judicial system requires respect and compliance, and attempting to subvert this process carries severe consequences, including the loss of appellate rights. Escaping justice does not provide the legal standing to seek it; instead, it forfeits it.
FAQs
| What was the key issue in this case? | The central issue was whether an escaped convict retains the right to appeal their conviction, despite evading legal processes. |
| What did the Supreme Court decide? | The Supreme Court ruled that by escaping from prison, Francisco Taruc impliedly waived his right to appeal his murder conviction. |
| What is the basis for the Court’s decision? | The decision is based on the Revised Rules of Criminal Procedure, which states that an accused who fails to appear at the promulgation of judgment without justifiable cause loses their remedies against the judgment. |
| Does this ruling apply to all types of cases? | While the ruling stems from a murder case, the principle of forfeiting appellate rights applies broadly to criminal cases where the accused escapes custody. |
| What happens if the accused is later re-arrested? | If the accused surrenders or is re-arrested within fifteen days from notice of judgment they can file a motion with the court and provide a justification for their absense, and it will be up to the court to consider that request. |
| Can someone appeal on behalf of an escaped convict? | No, the escaped convict loses their standing in court and cannot seek relief unless they surrender or submit to the court’s jurisdiction. |
| Is the right to appeal absolute? | No, the right to appeal is not absolute and can be waived, either expressly or implicitly, such as by escaping from custody. |
| What does this case mean for others facing criminal charges? | This case highlights the importance of complying with the legal process and not attempting to evade the law, as doing so can result in the loss of important legal rights, including the right to appeal. |
This case serves as a reminder that participation in the legal system carries responsibilities, and attempts to circumvent the process can have dire consequences for one’s legal standing. Escaping justice does not allow one to seek it.
For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.
Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People v. Taruc, G.R. No. 185202, February 18, 2009