G.R. No. 131149 -50 July 28, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. HIPOLITO DIAZ y DE GUZMAN, accused-appellant.

FACTS

Accused-appellant Hipolito Diaz was charged with two counts of rape committed against his minor daughter, Marissa Diaz. Upon arraignment, he pleaded not guilty, and the cases were consolidated for joint trial. After the prosecution rested its case, the trial court set multiple dates for the defense to present evidence. However, on all four scheduled hearings, the defense counsel, Atty. Alexander Yap, failed to appear despite due notice. No motions for postponement were filed. The accused-appellant himself was present during these hearings.
The trial court interpreted the repeated non-appearance of the defense counsel as a waiver of the accused’s right to present evidence. Consequently, it terminated the trial and considered the case submitted for decision based solely on the prosecution’s evidence. The court found Diaz guilty of two counts of rape, imposing the death penalty for each count due to the aggravating circumstance of relationship. The case was elevated to the Supreme Court for automatic review.

ISSUE

Whether the trial court violated the accused-appellant’s constitutional right to due process by denying him the opportunity to present his defense evidence.

RULING

Yes, the trial court violated the accused-appellant’s right to due process. The Supreme Court emphasized that the right to be heard and to present evidence is a fundamental constitutional guarantee. A valid waiver of this right cannot be presumed lightly, especially in capital offenses. The Court found that the trial court erred in construing the counsel’s repeated absences as an automatic waiver by the accused.
The legal logic is grounded on the principle that the severity of the potential penalty demands heightened scrutiny of procedural fairness. While the trial court’s desire for a speedy disposition is valid, it cannot override the accused’s substantive right to a full defense. The accused-appellant’s consistent presence at the hearings strongly indicated his desire to present evidence, but he was thwarted by his counsel’s neglect and his own inability to navigate court procedures. In such a scenario, where life is at stake, the court should have taken more proactive steps, such as appointing a new counsel de oficio, rather than outrightly foreclosing the defense’s opportunity to be heard. The denial of this opportunity constituted a deprivation of due process. Accordingly, the Supreme Court remanded the case to the trial court for the reception of the accused-appellant’s evidence and further proceedings.