GR L 41569; (October, 1984) (Digest)
G.R. No. L-41569 October 31, 1984
People of the Philippines, petitioner, vs. Hon. Salvador C. Reyes, as Judge of Branch III, Court of First Instance of Nueva Ecija; Hon. Norberto L. Cajucom, as City Judge of Palayan City; and Agaton Inocencio, respondents.
FACTS
An information for estafa was filed against Agaton Inocencio in the Palayan City Court. The prosecution listed over 70 witnesses and had already presented around 14. At a hearing on December 17, 1974, only 3 of 10 subpoenaed witnesses appeared. The city fiscal moved for the arrest of the absent witnesses and, upon denial, moved for postponement. The city judge denied both motions and instead prompted the defense to file a motion to dismiss.
The city fiscal filed a petition for certiorari with the Court of First Instance (CFI), alleging grave abuse of discretion. The CFI initially issued a restraining order but later dismissed the petition. It ruled that since the estafa case, involving P8,100, fell within the concurrent jurisdiction of the City Court and the CFI, the City Court was a co-equal court. Consequently, the CFI held it had no power to interfere via certiorari with the acts of a coordinate court.
ISSUE
Whether the respondent City Judge committed grave abuse of discretion in denying the prosecution’s motions for arrest of witnesses and for postponement, thereby warranting the annulment of the orders dismissing the case and the certiorari petition.
RULING
The Supreme Court dismissed the petition, finding no grave abuse of discretion. The legal logic rests on the trial court’s discretionary power to control the presentation of evidence. Under Section 6, Rule 133 of the Rules of Court, a court may stop further testimony on a point when the evidence is already so full that more witnesses cannot reasonably be expected to be additionally persuasive. This power must be exercised with caution.
Here, the prosecution had already presented 17 witnesses. The respondent City Judge, in denying further continuance, acted within his sound discretion to prevent the presentation of merely cumulative evidence. The Court cited Guinea vs. Vda. de Ramonal, which upheld a trial court’s rejection of cumulative testimony. There was no showing of a denial of substantial justice, as the prosecution had ample opportunity to present its case. The petition was bereft of merit.