MANILA, Philippines — In a landmark decision strengthening the administration of criminal justice, the Supreme Court (SC) En Banc explicitly adopted the “Fugitive Disentitlement Doctrine,” ruling that individuals who flee the Philippines to evade prosecution lose their standing to seek affirmative judicial relief. The ruling, promulgated on November 25, 2025, and penned by Associate Justice Samuel H. Gaerlan, reversed a regional trial court (RTC) order that had suspended a criminal case against Ricardo V. Yanson, Jr., a director involved in the long-running family feud over Vallacar Transit, Inc. (VTI).
Yansons’ Intra-Corporate War and Flight from Prosecution
The case is rooted in the bitter intra-corporate dispute within VTI, the parent company of the Ceres Liner bus franchise. Following a change in VTI leadership in July 2019, Ricardo V. Yanson, Jr. (Ricardo) and his siblings (the Yanson 4) took control of the head office, during which 55 VTI buses were temporarily housed at a compound Ricardo owned. When the rival faction, led by Leo Rey V. Yanson, recovered the buses, VTI filed criminal complaints against Ricardo for Carnapping and Grave Coercion.
Ricardo, who was aware of the criminal proceedings and the filing of Informations for Carnapping, executed a Special Power of Attorney for his lawyers and subsequently left the Philippines on March 7, 2020. Since then, he has continually evaded arrest, forcing the Municipal Trial Court in Cities (MTCC) to archive the Grave Coercion case. Ricardo’s counsel, however, continued to participate in the proceedings and successfully petitioned the RTC to suspend the criminal case, arguing that the unresolved intra-corporate dispute posed a prejudicial question.
Doctrine I: Intra-Corporate Dispute Does Not Suspend Public Crime
The Supreme Court first overturned the RTC’s finding of a prejudicial question. The Court clarified that the question of who the legitimate officers of VTI are does not relate to any of the elements of the public crime of Grave Coercion. Since the criminal action for Grave Coercion could proceed independently of the corporate dispute, and the guilt or innocence of Ricardo could be determined without awaiting the civil resolution, no suspension of the criminal trial was warranted. Furthermore, the Court reiterated that Grave Coercion is a public crime that can be prosecuted de oficio, making the issue of Nixon Banibane’s authority to file the complaint on VTI’s behalf immaterial.
Doctrine II: Custody of the Law Required for Fugitives
The centerpiece of the SC’s decision is the formal adoption of the Fugitive Disentitlement Doctrine as a mandatory principle in Philippine law. Previously, under the Miranda v. Tuliao ruling, a person could still seek judicial relief in a criminal case—and thus submit to the court’s jurisdiction—simply by having their lawyers file a pleading, even without being in the “custody of the law.”
The Court, however, carved out an essential exception for fugitives, finding that allowing an accused to continuously seek affirmative relief while willfully evading arrest negates the very concept of criminal jurisdiction and constitutes a mockery of the legal process.
The ruling emphasized that a person is considered a fugitive from justice for this purpose when they flee the Philippines with knowledge that an Information has been filed against them in court and a warrant of arrest is issued, demonstrating a clear intent to evade prosecution.
The SC stressed that this new mandate is necessary to ensure the enforceability of judicial judgments, discourage flight, and promote the equal protection of laws, which is often flouted when only individuals with sufficient financial means can afford to flee and still participate through counsel.
New Mandatory Procedure for Trial Courts
The Court established a new mandatory procedure for trial courts:
- If a warrant of arrest is unexecuted because the accused is outside the Philippine jurisdiction, the trial court may, after assessing the circumstances, declare the accused a fugitive from justice.
- A person declared a fugitive loses all standing in court and can no longer participate in the proceedings or seek judicial relief.
- The fugitive can only restore his or her standing before the court through voluntary surrender.
Based on these new guidelines, the Supreme Court reversed the RTC’s suspension order and remanded the Grave Coercion case back to the MTCC. The MTCC is directed to revive the case and proceed with the issuance of a warrant of arrest against Ricardo. If the warrant remains unserved due to Ricardo’s flight, the MTCC is authorized to declare him a fugitive from justice, effectively barring him from further participation in the criminal proceedings until he submits to the court’s custody.
