GR 123792; (March, 1999) (Digest)
G.R. No. 123792 March 8, 1999
MIRIAM DEFENSOR SANTIAGO, petitioner, vs. SANDIGANBAYAN, FIRST DIVISION, AND PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioner Miriam Defensor Santiago, then Commissioner of Immigration and Deportation, was charged before the Sandiganbayan with violation of the Anti-Graft and Corrupt Practices Act. The Information alleged she approved the legalization of aliens who arrived after January 1, 1984, in evident bad faith and manifest partiality, contrary to Executive Order No. 324. After pleading not guilty, the parties entered into a comprehensive stipulation of facts. They agreed that the case presented only legal questions, primarily whether the acts performed under her discretionary authority constituted a crime. Following the submission of memoranda, the case was deemed submitted for decision.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in reopening the case to allow the prosecution to present a complaining witness after the parties had stipulated on the facts and submitted the case for decision.
RULING
Yes. The Supreme Court granted the petition, annulling the Sandiganbayan’s resolutions. The legal logic is anchored on due process and the proper exercise of judicial discretion. While a court may reopen a case for further evidence, such action must be grounded on compelling reasons and must not prejudice the accused. Here, the parties had expressly stipulated that there were no factual issues, confining the case to pure questions of law. The proposed testimony of the complaining witness—to show the petitioner “berated” him and ordered the processing of applications without fees—was deemed irrelevant to the agreed legal issues. The alleged non-payment of fees was not even charged in the Information, and expediting action was within the petitioner’s prerogative as head of office. Crucially, the Sandiganbayan ordered the reopening without affording the accused an opportunity to rebut the new testimony, constituting a blatant denial of due process. This arbitrary act, which would unduly delay a long-pending case, amounted to grave abuse of discretion correctible by certiorari. The Court ordered the Sandiganbayan to decide the case based on the stipulated facts within six months.