People of the Philippines and Alfredo Quijano vs. Hon. Bernardo Salas, et al.
### Facts
Mario Abong was initially charged with homicide in the Court of First Instance of Cebu. Before arraignment, the prosecution motioned for a reinvestigation which led to an amended information with a recommendation for no bail. Abong pleaded not guilty. During the trial, Abong, exploiting the initial homicide information, deceived the Cebu city court into granting bail and escaped. Judge Salas, upon learning of this, canceled the bail bond and ordered Abong’s re-arrest. The prosecution requested the trial continue in Abong’s absence, per constitutional allowances for trial in absentia. However, Judge Salas suspended proceedings until Abong’s capture, prompting a petition for certiorari and mandamus by the petitioners to the Supreme Court.
### Issues
1. Can the trial in absentia proceed under the 1973 Constitution (Article IV, Section 19) notwithstanding the accused’s escape post-arraignment?
2. Does the escape of the accused constitute a waiver of his right to be notified of the trial and to participate in his defense?
3. Is the literal interpretation of the law by the respondent judge contrary to the spirit and intention of the constitutional provision for trial in absentia?
### Court’s Decision
The Supreme Court ruled in favor of proceeding with the trial in absentia. The Court clarified that the 1973 Constitution allows for trial in absentia under conditions that the accused has been arraigned, duly notified of the trial, and his absence is unjustified. Abong’s escape, having met these conditions, constituted a waiver of his right to be notified and participate. The Court admonished against a strictly literal reading of the law, promoting an interpretation that fulfills its purpose. It mandated the trial to continue and ordered an investigation into the lawyer who assisted Abong’s escape.
### Doctrine
The Supreme Court reaffirmed the conditions under which trial in absentia is permissible according to the 1973 Constitution: arraignment, notification, and unjustifiable absence of the accused. It underscored the principle that literal interpretation should not constrict the law’s purpose, emphasizing a more perceptive understanding that serves justice and the law’s intent.
### Class Notes
– **Trial in Absentia**: Permits the continuation of a trial even if the accused escapes post-arraignment, provided they had been notified and their absence is unjustified.
– **Waiver by Escape**: The act of escaping is deemed a waiver by the accused of his right to be present and notified of trial proceedings.
– **Literal vs. Purposeful Interpretation**: Courts are cautioned against a rigidly literal interpretation of laws, encouraged instead to seek their spirit and purpose to better serve justice.
– **1973 Constitution, Article IV, Section 19**: The article is central to understanding the legal framework for trial in absentia within the Philippine legal system.
### Historical Background
The case underscores a pivotal shift from previous jurisprudence which allowed an accused’s escape to indefinitely stall their trial. It reflects evolving legal standards towards ensuring the swift dispensation of justice, dissuading escape as a tactic to avoid trial, and emphasizing the broader interpretative responsibility of the judiciary to align procedural rules with constitutional intentions and the overarching goal of justice.
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