G.R. No. 111682 February 6, 1997
ZENAIDA REYES, petitioner, vs. COURT OF APPEALS and the PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioner Zenaida Reyes was convicted of falsification of a public document. After the prosecution rested, the presentation of her defense evidence was repeatedly postponed due to her illness and, more critically, the repeated absences of her counsel, Atty. Analuz Cristal-Tenorio. The trial court had rescheduled hearings multiple times with final warnings. On the last scheduled date, July 10, 1989, both petitioner and her counsel were absent. The court, on motion of the private prosecutor, declared that petitioner had waived her right to present evidence. Petitioner later submitted a medical certificate for her absence, but the court maintained its order. Consequently, the trial court rendered a judgment of conviction.
Petitioner, through a new counsel, appealed. She later filed a motion for new trial in the Court of Appeals in lieu of her appellant’s brief, arguing she was denied due process because her counsel’s negligence prevented her from presenting her defense. The appellate court denied the motion, noting the motion was self-prepared in a forensic style and that the grounds did not fall under the specific grounds for a new trial under the Rules of Court. It affirmed the conviction.

ISSUE

Whether the Court of Appeals erred in denying the motion for new trial, thereby upholding the conviction despite allegations that counsel’s negligence deprived petitioner of her right to present evidence and to due process.

RULING

The Supreme Court denied the motion for reconsideration and affirmed the rulings of the lower courts. The legal logic is anchored on the principle that a client is generally bound by the mistakes and negligence of their counsel. The right to due process is satisfied when a party has been given the opportunity to be heard. The records show petitioner was afforded this opportunity but failed to avail of it due to her and her counsel’s repeated absences, despite the trial court’s ample leniency and clear warnings. The Court found no compelling reason to deviate from the rule that negligence of counsel binds the client, as there was no showing of gross negligence so severe that it effectively deprived petitioner of her day in court. The Court of Appeals correctly held that the alleged negligence did not constitute a valid ground for new trial under Rule 121 of the Rules of Court, which requires errors of law or irregularities during trial, or newly discovered evidence. The failure to present evidence was a result of petitioner’s own and her counsel’s procedural defaults, not an error or irregularity committed by the trial court. Thus, no denial of due process occurred.