The provision provides that where the penalty
imposed by the RTC is reclusion perpetua or life imprisonment, an appeal is
made directly to this Court by filing a notice of appeal with the court which
rendered the judgment or final order appealed from and by serving a copy
thereof upon the adverse party. On the
other hand, a case where the penalty imposed is death will be automatically
reviewed by the Court without a need for filing a notice of appeal. However, People vs. Mateo G.R. Nos. 147678-87, July 7, 2004 modified
these rules by providing an intermediate
review of the cases by the CA where the penalty imposed is reclusion perpetua, life imprisonment, or death. Pursuant to Mateo’s ruling, the Court
issued A.M. No. 00-5-03-SC 2004-10-12, amending the pertinent rules
governing review of death penalty cases. Also affecting the rules on appeal is
the enactment of Republic Act No. (RA) 9346 or An Act Prohibiting the Imposition of the
Death Penalty in the Philippines, which took effect on June 29, 2006.
Under Sec. 2 of RA 9346, the
imposition of the death penalty is prohibited, and in lieu thereof, it imposes
the penalty of reclusion perpetua, when the law violated makes use of the
nomenclature of the penalties of the Revised Penal Code (RPC); or life imprisonment, when the
law violated does not make use of the nomenclature of the penalties of the RPC.
Consequently, in the provisions of the Rules of Court on appeals, death penalty cases are no longer
operational. It is a settled rule that substantiated factual findings of
the appellate court, affirming those of the trial court, are conclusive on the
parties and may not be reviewed on appeal. (People vs. Abon G.R. No. 169245 February 15,
2008 Velasco, Jr., J.)
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