The Supreme Court (SC) has laid down a clearer guide for judges on when a person can be considered a fugitive from justice, stressing that anyone who leaves — or refuses to return to — the country to avoid prosecution cannot seek relief from the courts unless they first submit themselves to its authority.
In a decision written by Associate Justice Samuel H. Gaerlan and released on 25 November, the Court En Banc spelled out what it means to be a fugitive, how trial courts should make that determination, and what legal consequences follow.
The justices explained that a person is deemed a fugitive not only when they escape after conviction, but also when they leave or stay abroad after charges are filed, with the clear intent of dodging arrest or prosecution.
According to the ruling, a fugitive is essentially someone who fails to appear when the law or a court requires it. The Court said that if a person leaves the Philippines knowing that a criminal Information and an arrest warrant have been issued, that alone can show an intent to evade prosecution — resulting in the loss of the right to join court proceedings or seek court intervention.
Before declaring someone a fugitive, trial courts must first establish two things: that an Information has been filed, and that a warrant of arrest has been issued. Proof that the accused knew of these developments — whether through actual notice or through documented attempts by law enforcement to serve the warrant — helps the court decide if the individual truly left to avoid arrest. Once the court confirms that the warrant couldn’t be served because the accused is abroad, it may declare that person a fugitive. From that point on, the accused has no standing before the court unless they voluntarily surrender.
The decision also reiterated that arrest warrants remain valid until served, and that cases may be archived if an accused remains un-arrested for six months.
The ruling stemmed from a petition by Vallacar Transit Inc. (VTI) and Nixon A. Banibane, who sought to overturn Regional Trial Court (RTC) orders that halted grave coercion proceedings against Ricardo V. Yanson Jr.
After prosecutors filed charges, Yanson questioned the finding of probable cause before the Department of Justice and later asked the court to suspend the case. The Municipal Trial Court in Cities (MTCC) initially granted his plea, but eventually ordered the implementation of the arrest warrant.
The Bureau of Immigration later informed the court that Yanson had already left the country when authorities attempted to serve the warrant. Despite this, he continued participating in the case through his lawyers via a Special Power of Attorney. VTI argued that Yanson’s departure meant neither he nor his lawyers had standing before the court.
While his lawyers continued to attend hearings, Yanson never showed up. After six months of failed attempts to serve the warrant, the MTCC archived the case. Even so, the RTC eventually issued rulings favorable to Yanson — prompting VTI and Banibane to elevate the issue to the SC.
In reversing the RTC, the High Court found that Yanson’s departure and continued absence signaled an intent to evade arrest, preventing the trial court from acquiring jurisdiction over him. The justices noted that courts cannot enforce a judgment against someone who stays outside Philippine territory, which compromises the administration of justice.
The Court said there is a need to reinforce the “fugitive disentitlement doctrine,” which bars individuals who refuse to submit to Philippine courts from invoking their authority. It sent the case back to the MTCC to determine whether the warrant remains unserved because Yanson is still abroad — and if so, to declare him a fugitive not entitled to any judicial relief.