People of the Philippines v Panfilo M.

Lacson
G.R. 149453, October 7, 2003
Callejo, Sr., J.:
Retroactivity of Procedural Rules:
FACTS: 1.
Respondent asserts that pursuant to a long line of jurisprudence and judicial practice in applying
penal law, Sec 8, Rule 117 of the Revised Rules of Crim Procedure should be applied
prospectively and retroactively without reservations, only and solely on the basis of its being
favorable to the accused.
He further asserts that the case law on retroactive application of penal laws should likewise
apply to criminal procedure it being a branch of criminal law.
In the petitioner’s comment on such motions, they contend that the prospective application of
Sec 8 in keeping with Sec5(5) Art III of the Constitution, which provides in part that the rules of
procedure which the court may promulgate shall not diminish, increase or modify substantial
rights. While sec 8 secures the rights of the accused, it does not and should not preclude the
equally important right of the State to public justice. If a procedural rule impairs a vested right, or
would work injustice, the said rule may not be given retroactive application.

ISSUE: W/N the petitioners seasonably filed their notice of appeal

RULING: 1.
In criminal litigations concerning constitutional issue claims, the Court, in the interest of justice,
may make the rule prospective where the exigencies of the situation make the rule prospective.
The retroactivity or non-retroactivity of a rule is not automatically determined by the provision of
the Constitution on which the dictate is based. Each constitutional rule of criminal procedure has
its own distinct functions, its own background or precedent, and its own impact on the
administration of justice, and the way in which these factors combine must inevitably vary with
the dictate involved.
OTHER IMPORTANT
NOTES:
By: Monica T. Buenaventura; created 2019