GR No 151258

Villareal vs People of the Philippines

GR No 151258        December 1, 2014

Facts:

      SC is asked to revisit the Decision held in the case involving the death of Leonardo “Lenny” Villa due to fraternity hazing. Some remaining matter were sought to be clarified and resolved. The matter include the effect of the Decision on the finality of the CA judgments insofar as respondents Tecson, et al are concerned.

        As decided, Dizon had a lowered criminal liability from the crime of homicide, while aggravating the verdict against Tecson et al from slight physical injuries. Apparently, Tecson et al applied for probation. The terms and conditions of their probation were allegedly completed. However, the said probation was applied for with the wrong court.

Issue:

     WON the completion by Tecson et al of the terms and conditions of their probation discharge them from their criminal liability?

Held:

         Tecson et al filed their Application for Probation with the wrong court. Part of the criminal justice system is the authority or jurisdiction of the court to adjudicate and decide the case before it.

         Under the Probation Law, the trial court may, after it shall have convicted and sentenced a defendant, and upon application of the said defendant within the period for perfecting an appeal, suspend the execution of the sentence and place the defendant on probation for such period and upon such terms and conditions as it may deem best. No probation shall be granted nor entertained when defendant has perfected an appeal from the judgment of conviction.

          Applicants of probation are not at liberty to choose the forum in which they may seek probation, as the requirement provided that the same should be done with the court which rendered the judgment of conviction. The said provision is substantive and not merely procedural. Considering therefore that the probation proceedings were premised on an unwarranted exercise of authority, the same is void.

      Probation is a special privilege granted by the state to penitent qualified offenders who immediately admit their liability and thus renounce their right to appeal. Some of the major purposes of the law are to help offenders to eventually develop themselves into law-abiding and self-respecting individuals, as well as to assist them in their reintegration in the community.

In any event, Tecson et al were ineligible to seek probation at the time they applied for it, as they had appealed their conviction to the CA.