G.R. No. L-10971; November 28, 1959
THE PEOPLE OF THE PHILIPPINES, THROUGH JESUS QUINTILLAN, ETC., petitioners, vs. URBANO JACA, ET AL., respondents.

FACTS

The Provincial Fiscal of Davao charged respondents Urbano Jaca, Bonifacio Jaca, and Go Bian Ling (an alien) before the Court of First Instance of Davao with a violation of the Anti-Dummy Law ( Commonwealth Act No. 108 , as amended) in relation to constitutional provisions. The prosecution alleged that during 1949-1955, the respondents were members of the partnership “Voctor Erickson and Company,” doing business as Mindanao Hardwood Lumber Company, with Go Bian Ling as manager. This company was engaged in manufacturing lumber from the timber concession of respondent Urbano Jaca. The prosecution presented evidence that the company sold large quantities of lumber at a price below the prevailing market rate. During the trial, the prosecution sought to introduce testimony from Fidel Reyes regarding the value of logs delivered by Mindanao Hardwood Lumber Company to Sta. Clara Lumber Company. The respondent judge, motu proprio, rejected the question, ruling that the amount of the transactions was not necessarily to be proved in the case. The other respondents also objected, arguing the question tended to establish an offense not alleged. The prosecution’s subsequent questions aimed at showing the logs’ value were paid to Mindanao Commercial Company, allegedly a dummy of Mindanao Hardwood, were similarly disallowed, prompting the filing of this petition for certiorari.

ISSUE

Whether the respondent judge committed a grave abuse of discretion in disallowing the prosecution’s question regarding the value of the logs delivered by Mindanao Hardwood Lumber Company to Sta. Clara Lumber Company, on the ground that it was irrelevant to the charge in the information.

RULING

The Supreme Court GRANTED the petition and SET ASIDE the ruling of the lower court. The Court held that the disallowed question was relevant to the issue raised in the information. The information specifically charged a violation under Section 2-A(3) of the Anti-Dummy Law, alleging that the Filipino respondents permitted and allowed the alien, Go Bian Ling, to intervene in the management and operation of the business of developing and exploiting a timberland forest as the manager of the partnership to which the timber license was conveyed. Evidence pertaining to the business transactions, such as the value of logs delivered, is material to establishing the nature and extent of the alien’s intervention in the management and operation of the business. The Court further stated that even in case of doubt as to the materiality of such evidence, it is more in keeping with the administration of justice to allow the question and answer, and to rule on its admissibility later when all evidence is in, rather than to exclude it prematurely. The question of relevancy should be considered in connection with other suppletory and correlative evidence.