This case has been cited 7 times or more.
|
2012-02-01 |
SERENO, J. |
||||
| Nevertheless, as in the case of an improvident guilty plea, an invalid waiver of the right to present evidence and be heard does not per se work to vacate a finding of guilt in the criminal case or to enforce an automatic remand of the case to the trial court.[47] In People v. Bodoso, we ruled that where facts have adequately been represented in a criminal case, and no procedural unfairness or irregularity has prejudiced either the prosecution or the defense as a result of the invalid waiver, the rule is that a guilty verdict may nevertheless be upheld if the judgment is supported beyond reasonable doubt by the evidence on record.[48] | |||||
|
2011-03-30 |
BERSAMIN, J. |
||||
| It is true that the Court has frequently deemed the failure of the trial courts to conduct an inquiry into the voluntariness and intelligence of the waiver to be a sufficient cause to remand cases to the trial courts for the purpose of ascertaining whether the accused truly intended to waive their constitutional right to be heard, and whether they understood the consequences of their waivers.[17] In People v. Bodoso,[18] a prosecution for a capital offense, we leaned towards the protection of the accused's constitutional right to due process by outlining the proper steps to be taken before deeming the right to present evidence as waived, thus: Henceforth, to protect the constitutional right to due process of every accused in a capital offense and to avoid any confusion about the proper steps to be taken when a trial court comes face to face with an accused or his counsel who wants to waive his client's right to present evidence and be heard, it shall be the unequivocal duty of the trial court to observe, as a prerequisite to the validity of such waiver, a procedure akin to a "searching inquiry" as specified in People v. Aranzado when an accused pleads guilty, particularly - | |||||
|
2010-12-13 |
MENDOZA, J. |
||||
| Although the admissibility of the evidence was not raised as in issue by the accused, it has been held that this Court has the power to correct any error, even if unassigned, if such is necessary in arriving at a just decision,[7] especially when the transcendental matter of life and liberty is at stake.[8] While it is true that rules of procedure are intended to promote rather than frustrate the ends of justice, they nevertheless must not be met at the expense of substantial justice. Time and again, this Court has reiterated the doctrine that the rules of procedure are mere tools intended to facilitate the attainment of justice, rather than frustrate it. Technicalities should never be used to defeat substantive rights.[9] Thus, despite the procedural lapses of the accused, this Court shall rule on the admissibility of the evidence in the case at bench. The clear infringement of the accused's right to be protected against unreasonable searches and seizures cannot be ignored. | |||||
|
2010-07-05 |
MENDOZA, J. |
||||
| On July 2, 2001, a decision was rendered by the trial court finding the accused guilty as charged and imposing upon him the penalty of death. The cases were then brought to this Court for automatic review[11] and were docketed as G.R. No. 149382 and G.R. No. 149383. On March 5, 2003, this Court resolved[12] to remand the cases to the trial court for proper disposition, particularly to ascertain the voluntariness of the accused on his waiver of his right to present evidence, as expressed in the April 2, 2001 Order[13] of the trial court; his understanding of its consequences; and the conduct of further proceedings, including receiving evidence, if the contrary would be found. | |||||
|
2006-10-30 |
VELASCO JR., J. |
||||
| The waiver is clear. The recent case of Valderama v. Macalde reiterated the three (3) essential elements of a valid waiver, thus: (a) existence of a right; (b) athe knowledge of the existence thereof; and, (c) an intention to relinquish such right. [25] These elements are all present in the case at bar. The three (3) executors, who were co-owners and titleholders of the said lot since 1954, were aware of their rights, and executed the Deed of Quitclaim in clear and unambiguous language to waive and relinquish their rights over Lot No. 3880 in favor of the heirs of Victoriana and Telesfora Reyes. Thus, the existence of a valid waiver has been positively demonstrated. Moreover, in People v. Bodoso, cited in Valderama, it was held that the standard of a valid waiver requires that it not only must be voluntary, but must be knowing, intelligent, and done with sufficient awareness of the relevant circumstances and likely consequences.[26] In the instant case, petitioners utterly failed to adduce any evidence showing that the assailed quitclaim was done absent such standard. Indeed, we note with approval the CAs apt application of the presumption that a person takes ordinary care of his concerns and that private transactions have been fair and regular.[27] | |||||
|
2004-03-17 |
CARPIO, J. |
||||
| person. However, to be a valid waiver, the accused must make the waiver voluntarily, knowingly, and intelligently.[14] In determining whether the accused can make a valid waiver, the court must take into account all the relevant circumstances, including the educational attainment of the accused. In the present case, however, respondent judge contends that complainants waived their right to counsel and insisted on their immediate arraignment. After reviewing the records and taking into account the circumstances obtaining in this case, we find that respondent judge did not properly apprise complainants of their right to counsel prior to their arraignment. Consequently, there was no basis for complainants' alleged | |||||
|
2004-02-26 |
AUSTRIA-MARTINEZ, J. |
||||
| We apply by analogy our ruling in People vs. Bodoso,[13] to wit:This Court notes with deep regret the failure of the trial court to inquire from accused-appellant himself whether he wanted to present evidence; or submit his memorandum elucidating on the contradictions and insufficiency of the prosecution evidence, if any; or in default thereof, file a demurrer to evidence with prior leave of court, if he so believes that the prosecution evidence is so weak that it need not even be rebutted. The inquiry is simply part and parcel of the determination of the validity of the waiver, i.e., "not only must be voluntary, but must be knowing, intelligent, and done with sufficient awareness of the relevant circumstances and likely consequences," which ought to have been done by the trial court not only because this was supposed to be an uncomplicated and routine task on its part, but more importantly since accused-appellant himself did not personally, on a person-to-person basis, manifest to the trial court the waiver of his own right. In the light of the foregoing, we have no other recourse but to set aside the judgment of the trial court convicting appellant and order the remand of the records of the case to the trial court to conduct further proceedings. | |||||