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Torres Jr., J.
FACTS
HELD
Trial may proceed notwithstanding the absence of
the accused provided that hes been duly notified
& his failure to appear is unjustifiable. The
requisites then of a valid trial in absentia are: (1)
the accused has already been arraigned, (2) hes
been duly notified of the trial, and (3) his failure
to appears unjustifiable5
6 Gundayao, et al. v CA
7 Cruz I, Constitutional Law (1995)
Torres Jr., J.
8 Galvez v. Eduardo
9 See Art. 315 (RPC)