GR 1304; (January, 1904) (Digest)
March 7, 2026GR 1267; (January, 1904) (Digest)
March 7, 2026G.R. No. 1298 : January 14, 1904
THE UNITED STATES, complainant-appellee, vs. JUAN SINGUIMUTO, defendant-appellant.
FACTS:
The provincial fiscal filed a complaint charging Juan Singuimuto with estafa. The information alleged that Singuimuto, a designated seller of government rice in Batangas, received 300 sacks of rice from Lieutenant William H. Bell, the U.S. military commissary officer. The rice was obtained through two orders issued by Lt. Bell (one for 100 sacks on July 16, 1902, and another for 200 sacks on October 13, 1902) and was delivered to Singuimuto’s agent, Isabelo Javier. The rice was to be sold on commission, with the proceeds to be delivered to the municipal president for remittance to the government. Singuimuto failed to account for or pay the value of the rice and denied having received it. After trial, the Court of First Instance convicted Singuimuto. Following his conviction and appeal, Singuimuto moved for a new trial based on “newly discovered evidence,” submitting affidavits from nine witnesses who would allegedly testify that the prosecution witness Isabelo Javier’s testimony was untrue.
ISSUE:
Whether the trial court erred in granting the defendant’s motion for a new trial based on the proffered “newly discovered evidence.”
RULING:
The Supreme Court reversed the order granting a new trial. The Court held that the evidence presented in support of the motion did not constitute “newly discovered evidence” warranting a new trial under Section 42 of General Orders, No. 58. The affidavits were merely for the purpose of impeaching the testimony of a prosecution witness (Isabelo Javier) and were cumulative in nature. The defendant failed to exercise due diligence, as he knew of the existence of these witnesses at the time of the trial but did not seek summonses for them, request a continuance, or inform the court of their importance. The policy of the courts requires parties to exercise care, diligence, and vigilance in securing and presenting evidence at trial. A new trial is not granted for evidence that is merely impeaching, cumulative, or which could have been discovered and produced with reasonable diligence. Consequently, the motion for a new trial should have been denied.
