Sunday, January 25, 2009

Garcia, et. al. vs. People G.R. No. 106531, November 18, 1999



Facts:
The Provincial Fiscal of Guimaras filed with the RTC an information charging petitioners with murder for the killing of one Jose Estrella. After due trial, the trial court promulgated its decision convicting petitioners of the crime charged and sentencing each of them to the penalty of reclusion perpetua. Petitioners filed a motion for reconsideration of the decision. The trial court denied the motion. Petitioners did not interpose an appeal from the decision by the filing of a notice of appeal. Thus, the decision became final.


Issue: Whether or not the SC must automatically review a trial court’s decision convicting an accused of a capital offense and sentencing him to reclusion perpetua


Held:
It is only in cases where the penalty actually imposed is death that the trial court must forward the records of the case to the SC for automatic review of the conviction.

As the petitioners did not file a notice of appeal or otherwise indicate their desire to appeal from the decision convicting them of murder and sentencing each of them to reclusion perpetua, the decision became final and unappealable.

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