APPLICATION OF NEYPES DOCTRINE IN CRIMINAL CASES:

     While Neypes involved the period to appeal in civil cases, the Court's pronouncement of a "fresh period" to appeal should equally apply to the period for appeal in criminal cases under Section 6 of Rule 122 of the Revised Rules of Criminal Procedure. (Judith Yu vs. Hon. Rosa Samson-Tatad, G. R. No. 170979, February 9, 2011, brion, j.).