Unique nature of appeals in criminal cases

The unique nature of an appeal in a criminal case is that the appeal throws the whole case open for review of all its aspects.[1]The appellate court is duty-bound to correct, cite and appreciate errors in the appealed judgment, whether they are assigned or unassigned.[2]

The Supreme Court has the authority to review matters not specifically raised or assigned as an error by the parties if their consideration is necessary to arrive at a just resolution of the case.[3] An examination of the entire records of a case may be explored for the purpose of arriving at a correct conclusion.[4] It is incumbent upon the appellate court to render such judgment as law and justice dictate, whether it be favorable or unfavorable to the accused.[5] The rationale behind the rule stems from the recognition that an accused waives the constitutional safeguard against double jeopardy once he appeals from the sentence of the trial court.[6] This rule is strictly observed, particularly where the liberty of the accused is at stake.[7]

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In the case of Villarosa v. People (G.R. Nos. 233155-63. July 17, 2018), the High Court said it would be most unfortunate if, as Villarosa alleged, the Sandiganbayan failed to cautiously examine facts and circumstances that are of substance and value which, if considered, would be favorable to him as an accused. An allegation of the perfunctory manner by which it handed down its guilty verdict constrained the Supreme Court to modify the rules of procedure in the interest of substantial justice. In this case of Villarosa, particularly at risk are Villarosa's right to liberty and the quality of the remaining years of his life.[8]In conclusion, the Supreme Court sustained Villarosa's position that courts are required to take "a more than casual consideration" of every circumstance or doubt proving the innocence of an accused. As held in Ruzol v. Sandiganbayan, et al.:[9]
[A]n accused in a criminal case is presumed innocent until the contrary is proved and that to overcome the presumption, nothing but proof beyond reasonable doubt must be established by the prosecution.
As held by the Court in People v. Sitco (G.R. No. 178205):
The imperative of proof beyond reasonable doubt has a vital role in our criminal justice system, the accused, during a criminal prosecution, having a stake interest of immense importance, both because of the possibility that he may lose his freedom if convicted and because of the certainty that his conviction will leave a permanent stain on his reputation and name.
In Rabanal v. People (G.R. No. 16085), the Court further explained:
Law and jurisprudence demand proof beyond reasonable doubt before any person may be deprived of his life, liberty, or even property. Enshrined in the Bill of Rights is the right of the petitioner to be presumed innocent until the contrary is proved, and to overcome the presumption, nothing but proof beyond reasonable doubt must be established by the prosecution. The constitutional presumption of innocence requires courts to take "a more than casual consideration" of every circumstance [or] doubt proving the innocence of petitioner. 
Verily, an accused is entitled to an acquittal unless his or her guilt is shown beyond reasonable doubt and it is the primordial duty of the prosecution to present its side with clarity and persuasion, so that conviction becomes the only logical and inevitable conclusion, with moral certainty.
As explained by this Court in People v. Berroya (G.R. No. 122487):
The necessity for proof beyond reasonable doubt lies in the fact that "(i)n a criminal prosecution, the State is arrayed against the subject; it enters the contest with a prior inculpatory finding in its hands; with unlimited means of command; with counsel usually of authority and capacity, who are regarded as public officers, and therefore as speaking semi-judicially, and with an attitude of tranquil majesty often in striking contrast to that of defendant engaged in a perturbed and distracting struggle for liberty if not for life. These inequalities of position, the law strives to meet by the rule that there is to be no conviction when there is a reasonable doubt of guilt."
Indeed, proof beyond reasonable doubt does not mean such a degree of proof, excluding possibility of error, produces absolute certainty; moral certainty only is required, or that degree of proof which produces conviction in an unprejudiced mind.[10]

Cliche as it may sound, in criminal law, the evidence for the prosecution must stand or fall on its own weight and cannot be allowed to draw strength from the weakness of the defense.[11]

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[1]Benabaye v. People, 755 Phil. 144, 157 (2015).

[2]See People v. Ramirez, G.R. No. 219863, March 6, 2018; People v. Santos, G.R. No. 223142, January 17, 2.018; Rimando v. People, G.R. No. 229701, November 29, 2017.; Tabobo III v. People, G.R. No. 220977, June 19, 2017 (Resolution); People v. Samson, 768 Phil. 487, 495 (2015); and People v. Dahil, et al., 750 Phil. 212, 225 (2015).

[3]People v. Miranda, G.R. No. 229671, January 31, 2018; Digan v. Malines, G.R. No. 183004, December 6, 2017.; Greenstar Express, Inc. v. Universal Robina Corporation, G.R. No. 205090, October 17, 2016, 806 SCRA 125, 156; Philippine Commercial International Rank v. Gomez, G.R. No. 199601, July 25, 2016 (Notice); Dela Cruz v. People, 776 Phil. 653, 673 (2016); and Grace Marine Shipping Corp. et al. v. Alarcon, 769 Phil. 474,497(2015).

[4]People v. Ragasa, G.R. No. 202863, February 21, 2018.

[5]People v. Miranda, G.R. No. 229671, January 31, 2018; Escalante v. People, G.R. No. 218970, June 28, 2017; and People v. Bugarin, G.R. No. 224900, March 15,2017.

[6]People v. Miranda, G.R. No. 229671, January 31, 2018, and People v. Bugarin, G.R. No. 224900, March 15,2017.

[7] Tabobo III v. People, G.R. No. 220977, June 19, 2017 (Resolution); People v. Samson, 768 Phil. 487, 495 (2015); and People v. Dahil, et al., 750 Phil. 212, 225 (2015).

[8]In each of the nine (9) counts of Violation of Section 3 (e) of R.A. No. 3019, Villarosa was sentenced to suffer an indeterminate penalty of imprisonment of six (6) years and one (1) month as minimum up to ten (10) years as maximum, with perpetual disqualification from holding public office. Also, he claims to be already 75 years old. (Rollo, pp. 73, 380-381).

[9]709 Phil. 708(2013).

[10]Ruzol v. Sandiganbayan, et al, supra, at 750. (Citations omitted). See also Saguin, et al. v. People, 113 Phil. 614, 629-630 (2015).

[11] People v. CaƱete, 433 Phil. 781, 795 (2002) and People v. Dimalanta, 483 Phil. 56, 68 (2004).

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