
MANILA – Government lawyers may ask the Supreme Court to review the “fugitive disentitlement doctrine” to further limit the legal options of fugitives like former Representative Elizaldy Co and trader Charlie “Atong” Ang, Senate President Pro Tempore Panfilo “Ping” M. Lacson said.
Lacson made the statement on X after Co’s camp claimed that the doctrine, embodied in the Supreme Court’s November 25, 2025 ruling (GR 259337), does not apply to him. The ruling clarified rules on fugitive status and bars fugitives from seeking judicial relief unless specific conditions are met.
“Paging SolGen (Solicitor General): It may be wise to ask the Court to revisit the ‘fugitive disentitlement doctrine’ in GR 259337 dtd Nov. 25, 2025 that refined Miranda vs Tuliao in relation to the cases of Zaldy Co and Atong Ang,” Lacson said.
Co’s camp, challenging from Sweden the Ombudsman’s resolution that led to graft and malversation charges against him, argued that the doctrine should not apply to his Sandiganbayan cases. It claimed that judgment has not been rendered against Co, “so he is not an appellant; neither is he an escapee or bail jumper.”
Co is wanted by authorities, including the Senate Blue Ribbon Committee, which Lacson chairs, over corruption in anomalous flood control projects. Ang is being tracked down in connection with the case of the missing sabungeros. In a December 10, 2025 resolution, the Sandiganbayan declared Co a “fugitive from justice.”
The Supreme Court’s November 2025 ruling creates an exception to Miranda vs. Tuliao (G.R. No. 158763, March 31, 2006), allowing individuals to seek relief in criminal cases while staying outside Philippine jurisdiction only if they are not fugitives. The court defined a fugitive from justice as someone “who not only flees after conviction to avoid punishment, but one who also flees after being charged to avoid prosecution,” with the essential element being the intent to evade prosecution or punishment.
The ruling further states that if an accused fails to execute a warrant of arrest due to being outside the Philippines, the court may declare the person a fugitive from justice, causing them to lose standing in court and the ability to seek judicial relief. Custody through arrest or voluntary surrender must first be obtained before the case can proceed.





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