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PEOPLE v. JOSEFINA A. ESPARAS

## FACTS:

The accused, Josefina A. Esparas, was charged with violation of R.A. No. 6425 for importing 20 kilograms of "shabu." After her arraignment, the accused escaped from jail and was tried in absentia. The trial court found her guilty and imposed the death penalty. The accused remains at large, leading to the issue of whether or not the court will proceed to automatically review her death sentence. The court looked into the 1910 case of U.S. vs. Laguna, where it was held that the power of the court to review a decision imposing the death penalty cannot be waived by the accused or the courts. The court found that the judgment of conviction and sentence imposed by the trial court does not conclude the trial of the accused, as it is not final until reviewed by the Supreme Court. The court also cited the 1935 Constitution and the Rules of Court of 1940 and 1964, which require the transmission of records of cases where the death penalty is imposed to the Supreme Court for review and judgment. Previous case law reiterated that the withdrawal of an appeal by a death convict does not remove the case from the jurisdiction of the Supreme Court. The court also held that the escape of a death convict does not relieve the court of its duty to review the conviction.

ISSUES:

  1. Whether the Supreme Court should proceed with the automatic review of the death sentence of Josefina A. Esparas, who remains at large.

RULING:

The Supreme Court held that the automatic review of death sentences is mandatory and cannot be waived, regardless of whether the accused remains in custody or escapes from jail. The review ensures that a decision authorizing the State to take life is free from error to the highest possible standard. Thus, the review must proceed irrespective of the accused's current status as an escapee.

PRINCIPLES:

  1. Inviolability of Automatic Review: The judgment of conviction imposing the death penalty by a trial court is not final and has no force until reviewed by the Supreme Court.

  2. Mandatory Jurisdiction: The Supreme Court has the mandatory jurisdiction to review all cases where the death penalty has been imposed, which cannot be affected by an accused’s actions, such as escape or withdrawing an appeal.

  3. Protection of the Accused: The automatic review process is designed to protect the accused, ensuring an additional level of scrutiny before the execution of the highest penalty - death.

  4. Judicial Responsibility: It is the duty of the Supreme Court to review death penalty cases to confirm the conviction's legality and justice without being influenced by any outside factors, including public opinion on crime or the accused’s conduct after sentencing.

  5. Constitutional and Procedural Basis: The requirement for automatic review is grounded in constitutional provisions and procedural laws that dictate the need for higher scrutiny in death penalty cases.

  6. Assurance of Rights: Even after conviction, the rights of the accused, particularly in capital punishment cases, demand rigorous protection to prevent any miscarriage of justice.

  7. Non-Cessation of Rights Due to Conviction: The rights of the accused do not cease with conviction, emphasizing the importance of careful judicial review in death penalty scenarios.