**Facts:**
The Supreme Court faced the task of resolving the motions filed by respondent Panfilo M. Lacson in connection to the Supreme Court’s April 29, 2003 Resolution which granted the petitioner’s motion for reconsideration, leading to various legal and procedural questions in the course of the case.
The case originated from the provisional dismissal of criminal cases against Lacson by Judge Wenceslao Agnir, Jr. on March 29, 1999, for lack of probable cause. The dismissal purportedly did not have the express consent of Lacson nor notice to the offended parties as required by Section 8, Rule 117 of the Revised Rules of Criminal Procedure (RRCP). The Department of Justice refiled the criminal charges on June 6, 2001, beyond the two-year bar mandated by the new rule which took effect on December 1, 2000.
Respondent Lacson filed motions challenging the validity of the refiling and whether it violated his constitutional right to speedy trial and the due process clause, among other concerns. The legal journey included Lacson’s initial appeal to the Court of Appeals (CA) invoking the right against double jeopardy. After an unfavorable decision in the CA (which addressed Section 8, Rule 117 of the RRCP), he brought the matter to the Supreme Court.
The Supreme Court initially decided in favor of Lacson on May 28, 2002, resolving to uphold the two-year time-bar and ordering the remand to the trial court to determine if due process was observed in the provisional dismissal of the original cases. However, upon the petitioners’ motion for reconsideration, the Court’s April 29, 2003 Resolution reversed its initial stance, leading to Lacson filing various motions including the Omnibus Motion, the Motion for Reconsideration, the Supplement to Motion for Reconsideration, and the Motion To Set for Oral Arguments.
**Issues:**
1. Whether the Supreme Court’s en banc members appointed after the oral arguments should voluntarily inhibit from the case;
2. Whether the case should be set for oral arguments;
3. Whether Section 8, Rule 117 of the RRCP, particularly the two-year time-bar for the revival of provisionally dismissed cases, applies retroactively or prospectively;
4. Whether Lacson’s constitutional rights to speedy trial and due process were violated by the revival of the criminal cases beyond the two-year bar.
**Court’s Decision:**
1. **Inhibition of Justices**: The motion for the inhibition of Justices Corona, Austria-Martinez, Morales, Callejo, Sr., and Azcuna was denied. The Court held that the grounds for inhibition had been passed upon in previous resolutions and no new substantial arguments were made.
2. **Oral Arguments**: The motion to set the case for oral arguments was denied, as the issues had been extensively discussed in the submitted motions and replies.
3. **Time-bar under Section 8, Rule 117**: The Court ruled that Section 8 should be applied prospectively, not retroactively. The Court based its decision on its power under the Constitution to promulgate rules that do not diminish, increase, or modify substantive rights, and the policy that rules of procedure must not work injustice. The Court found that the new rules were fair for both the State and the accused, and that a retroactive application would unduly handicap the State’s right to prosecute.
4. **Due Process and Speedy Trial**: The Court determined that Lacson’s contentions of due process violation and breach of the right to a speedy trial were without merit, stating that the refiling of cases within the two-year period as counted from the effectiveness of the new rule did not infringe upon his rights.
**Doctrine:**
– The Supreme Court holds the power to determine whether rules of procedure apply prospectively or retroactively based on considerations of fairness and justice, without infringing upon the substantive rights of the litigants.
– Section 8 of Rule 117 of the Revised Rules of Criminal Procedure is to be applied prospectively, ensuring the State and the accused are given a fair opportunity to abide by the specified time-bar for the revival of provisionally dismissed cases.
– Judicial admissions bind the client only if they are made voluntarily for the purpose of dispensing with proof, distinct and formal, and for the express purpose of litigation.
**Class Notes:**
– **Rule 117, Section 8 of the RRCP**: Establishes a one-year or two-year time-bar for the State to revive provisionally dismissed criminal cases, with the express consent of the accused and notice to the offended party.
– **Retroactivity of Procedural Rules**: Procedural rules are typically applied retroactively to pending cases unless it is not feasible or would result in injustice.
– **Judicial Admissions**: Statements made by counsel in a judicial proceeding, admitted for the purpose of avoiding proof, and binding on the party.
**Historical Background:**
The case reflects tensions between the State’s rights to prosecute versus the constitutional protection of speedy trial and due process for the accused. It underscores the evolving jurisprudence on the retroactive application of procedural law reforms, particularly in the context of criminal proceedings, and the Supreme Court’s power to interpret such laws while balancing the rights and interests of the parties involved.
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