Monday, August 25, 2014

Case disgest: Spouses Bello vs CA

Civil Code Article 10: In case of doubt in the interpretation and application of laws, it is presumed that the lawmaking body intended right and justice to prevail.

Spouses Bello Petitioners
Vs.
CA, Hon. Francisco Llamas, Judge of Pasay City Court and Republic of the Philippines Respondents



Facts:                    On August 25, 1970, spouses Bello were charged with estafa for allegedly having misappropriated a lady’s ring with a value of P1, 000.00 received from them from Atty. Prudencio De Guzman for sale on commission basis. After trial, they were convicted and sentenced. They then filed an appeal to the Court of First Instance and after that to the respondent city court which was also dismissed and ordered for execution of judgment “for having been erroneously addressed to this court”. Petitioner spouses then filed for prohibition and mandamus against the People and respondent city court to elevate their appeal to the Court of Appeals which was again dismissed after finding that the city court’s judgment was directly appealable to it. Still, the couple moved for reconsideration and stressing the merits of their appeal and of their defense but was again denied “for lack of sufficient merit”.


Issue:                    Whether or not the Court of Appeals erred in dismissing the case due to wrong procedure.
                                Whether or not the execution of judgment will be issued a mandamus


Ruling:                  Decision of CA to dismiss petition is set aside. Mandamus is issued for the execution of its judgment of conviction. And, said city court is commanded to elevate petitioner’s appeal from its judgment to the Court of Appeals for the disposition on the merits.



                                The Court of Appeals should have not dismissed the appeal but should have certified the case to the proper court. It is of the essence of judicial duty to construe statutes so as to avoid such deplorable result of injustice and absurdity and that a literal interpretation is to be rejected if it would be unjust or lead to absurd results.

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