“[T]he [Supreme] Court defined a fugitive from justice as one who not only flees after conviction to avoid punishment, but also includes those who, after being charged, flee to avoid prosecution”
“A FUGITIVE from justice is a person who attempts to evade law enforcement by fleeing the jurisdiction… [T]he [Supreme] Court defined a fugitive from justice as one who not only flees after conviction to avoid punishment, but also includes those who, after being charged, flee to avoid prosecution.” (Vallacar Transit, Inc. v. Yanson, G.R. 259337, Nov. 25, 2025 citing Marquez, Jr. v. Commission on Elections).
“A person who has not submitted himself to the jurisdiction of the· court has no right to ·invoke the processes of that court.
“Jurisdiction of the courts is, therefore, required to ensure that the court’s judgment would be enforceable… [which] will not be met if an accused… is a fugitive or outside the territorial jurisdiction of the Philippine court…” (Op cit.)
It is necessary to distinguish custody of the law with jurisdiction over the person of the accused.
“[A] person applying for admission to bail must be in the custody of the law or otherwise deprived of his liberty… [while a] person who has not submitted himself to the jurisdiction of the court has no right to invoke the processes of that court.” (Op cit. citing Padua v. People)
In applying the case of Miranda v. Tuliao, the Supreme Court explained that, “in adjudication of other reliefs sought by accused, it requires neither jurisdiction over the person of the accused, nor custody of law over the body of the person.”
“Thus, except in applications for bail, it is not necessary for the court to first acquire jurisdiction over the person of the accused to dismiss the case or grant other relief.” (Op cit. cited in Vallacar Transit, Inc. v. Yanson)
Simply said, “once an accused participates in the case and asks for affirmative relief, [they are] deemed to have submitted… to the jurisdiction of the court. Even if the accused is not physically under the custody of the court, the court may proceed to adjudicate and grant or deny the reliefs sought.” (Op cit. citing Miranda and Tuliao)
In Vallacar Transit, Inc. v. Yanson (Vallacar), accused, Ricardo, was not physically present in court, even for his arraignment.
The court never acquired custody over him because he had left the Philippines and was only represented by counsel during the proceedings.
Following the Miranda ruling, “Ricardo is deemed to have submitted himself to the jurisdiction of the courts by filing his Motion to Suspend Proceedings… and is allowed to participate in the criminal proceedings.”
However, in Vallacar, the Supreme Court “finds it imperative to carve out an exception to the pronouncements in Miranda when the criminal case involves fugitives from justice.”
“Custody over their persons [fugitives], either by their arrest or voluntary surrender, must first be secured before a case against them may proceed.” Jurisdiction over them would not be acquired “simply by the filing of any pleading or by participating in the case through [their] lawyers.” (Op cit.)
“The [Supreme] Court… acknowledges that Miranda has allowed those who have not been under the custody of the courts, such as Ricardo to seek affirmative relief in criminal cases while they willfully evade arrest.”
This being said, Ricardo should not be “allowed to continue seeking affirmative relief before the courts despite his apparent flight from the Philippines…” (Op cit.)
The Supreme Court laid down the procedure to be observed, before an individual is declared as a fugitive from justice, by the court where the Information is filed.
“After finding probable cause, the court shall issue a warrant of arrest [which]… shall be implemented within 10 calendar days from its receipt by the executing officer.” (Op cit.)
“If there is a failure to execute the warrant of arrest by reason that the accused is outside the Philippine jurisdiction, as stated in the executing officer’s return, the court may, either by motion or motu proprio, and after assessment of the circumstances of the case, declare the accused a fugitive from justice.” (Op cit.)
“From then, such person loses their standing in court, can no longer participate in the proceedings, and cannot seek any judicial relief. They can only restore [their] standing before the court through voluntary surrender.” (Op cit.)
The Supreme Court found it to be “high time to also apply [the fugitive disentitlement doctrine] to those who have committed a crime or are suspected of committing a crime, and fled outside the Philippines’ jurisdiction.
“Adopting such mandate strengthens the justice system and due process rights, which both the accused and the State are equally entitled to.” (Op cit.)
