People v. Roxas (G.R. No. 172604; August 17, 2010)


CASE DIGEST: PEOPLE OF THE PHILIPPINES V. VENANCIO ROXAS

FACTS: Venancio Roxas was found guilty by the RTC of the crimes of Kidnapping and Serious Illegal Detention with Frustrated Murder, Violation of the Anti-Carnapping Act of 1972, and Theft.
In the automatic review of the decision, the accused contends that his constitutional rights were violated since then Justice Secretary Hernando Perez was present at the trial, thus imputing bias upon the trial judge in convicting him. ADVERTISEMENT: Work from home! Be an online English tutor. Earn at least PHP100/hour.

ISSUE:  Whether or not the presence of the Justice Secretary imputes bias upon the trial court, thus, violating the accused right to due process?
HELD: No. There is no basis for appellant's allegation that he was deprived of due process of law and that the trial conducted was far from impartial and fair. The imputation of bias and partiality is not supported by the record. The fact that the trial judge opted to believe the prosecution's evidence rather than that of the defense is not a sign of bias.


Even if the RTC had allowed the presence of then Secretary Hernando Perez and the media, there is no sufficient basis to show that their presence or pervasive publicity unduly influenced the court's judgment. Before we could conclude that appellant was prejudiced by the presence of the media and Secretary Perez, he must first show substantial proof, not merely cast suspicions. There must be a showing that adverse publicity indeed influenced the court's decision. There was none in the present case.

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