GR 163996; (June, 2005) (Digest)
G.R. No. 163996 ; June 9, 2005
JUAN G. RIVERA, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
Petitioner Juan G. Rivera, the municipal mayor of Guinobatan, Albay, was charged before the Sandiganbayan with twelve counts of falsification of public documents and one count of malversation of public funds. The charges stemmed from the alleged misuse of a calamity fund intended for victims of a volcanic eruption. After the prosecution rested its case, petitioner’s counsel manifested an intent to file a demurrer to evidence. The Sandiganbayan’s order, however, recorded that petitioner would file a demurrer without leave of court. Petitioner subsequently filed such a demurrer.
The Sandiganbayan, applying Section 23, Rule 119 of the Revised Rules of Criminal Procedure, deemed petitioner to have waived his right to present evidence and submitted the case for decision based solely on the prosecution’s evidence. It then rendered a decision convicting petitioner on all counts, imposing an aggregate imprisonment of approximately 140 years. Petitioner’s motion for reconsideration, which included a plea to be allowed to present evidence, was denied.
ISSUE
Whether the Sandiganbayan erred in denying petitioner the opportunity to present his evidence after filing a demurrer to evidence without leave of court.
RULING
Yes. The Supreme Court granted the petition and set aside the Sandiganbayan’s rulings. The Court emphasized that while procedural rules are essential for the orderly administration of justice, they must not be applied so rigidly as to override substantial justice. The filing of a demurrer to evidence without leave of court results in a waiver of the right to present evidence and allows the court to render judgment on the prosecution’s evidence alone.
However, the Court found that the circumstances warranted a relaxation of the rule. The penalty imposed—effectively a double-life sentence—involved a transcendental matter of liberty. The Court noted that the record did not sufficiently show that the Sandiganbayan conducted a “searching inquiry” to ensure petitioner fully understood the consequences of his counsel’s action, particularly the waiver of his constitutional right to be heard and present evidence. Moreover, an assessment of the prosecution’s evidence indicated it was not so strong as to conclusively prove guilt, leaving room for reasonable doubt that the defense evidence could address. To prevent a possible miscarriage of justice, the Court remanded the case to the Sandiganbayan to allow petitioner to present his evidence.