The Supreme Court has ruled that individuals who flee to evade arrest or prosecution forfeit the right to seek any form of judicial relief until they voluntarily surrender.
In a decision penned by Associate Justice Samuel Gaerlan for the Court En Banc, the justices clarified that fugitive status applies not only to convicts who escape punishment but also to persons who leave the country or go into hiding after being charged, with the intent of evading arrest.
The Court explained that physical non-appearance when required by law, coupled with knowledge that an information and arrest warrant have been issued, signals evasion and strips the accused of standing before the courts.
A warrant becomes the operative trigger for fugitive status, and those unable to be served due to absence may be formally declared fugitives. From that point, they can no longer participate in proceedings through counsel or seek court intervention.
The ruling arose from the grave coercion case involving Ricardo Yanson Jr., Vallacar Transit, Inc. (VTI), and Nixon Banibane. Despite lawyers filing pleadings under Special Power of Attorney, the Municipal Trial Court could not enforce the arrest warrant after Yanson left the country, leading to the case being archived.
Reversing the lower court, the Supreme Court held that Yanson’s departure demonstrated intent to evade arrest, preventing the RTC from acquiring jurisdiction over his person.
The Court carved an exception to the Miranda v. Tuliao principle, ruling that participation through counsel is insufficient for fugitives; custody — through arrest or voluntary surrender — is required before proceedings may continue.
Senior Associate Justice Marvic Leonen agreed with applying the fugitive disentitlement doctrine but suggested suspending the criminal case due to ongoing intra-corporate disputes within the Yanson family. Associate Justice Alfredo Benjamin Caguioa supported the clarified definition of a fugitive but would have denied the petition for the same reason.
The case was remanded to the MTCC to determine whether the warrant against Yanson remained unserved solely due to his being abroad and, if so, to formally declare him a fugitive no longer entitled to judicial relief.