GR 143689; (November, 2002) (Digest)
G.R. Nos. 143689-91 November 12, 2002
SIXTO M. BAYAS and ERNESTO T. MATUDAY, petitioners, vs. THE SANDIGANBAYAN (FIRST DIVISION), THE PEOPLE OF THE PHILIPPINES and THE OFFICE OF THE SPECIAL PROSECUTOR, respondents.
FACTS
Petitioners Sixto M. Bayas and Ernesto T. Matuday, the municipal treasurer and municipal mayor, respectively, of Kabayan, Benguet, were charged before the Sandiganbayan with violation of Section 3(e) of R.A. No. 3019 and two counts of malversation through falsification. During the pretrial conference on December 10, 1999, the parties submitted a “Joint Stipulation of Facts and Documents” duly signed by the petitioners, their counsel (Atty. Jose M. Molintas), and the Ombudsman prosecutor. The stipulation included admissions that the accused made the disbursements of P510,000.00 and P55,000.00, and jointly admitted several documentary exhibits. Subsequently, Atty. Molintas withdrew as counsel. On April 26, 2000, the petitioners, through their new counsel, filed a Motion to Withdraw the Joint Stipulation, specifically seeking to withdraw the admission of the disbursements and several exhibits, invoking their constitutional right to be presumed innocent. The Sandiganbayan denied the motion, finding no fraud or serious mistake vitiating the consent to the stipulation and ruling that the mere disadvantage to the defense was not a ground for withdrawal.
ISSUE
May pretrial stipulations of facts duly signed by the accused and their counsel be unilaterally withdrawn before the commencement of the trial?
RULING
No. The Supreme Court denied the petition and upheld the Sandiganbayan’s orders. Stipulations of facts freely and voluntarily made are valid and binding and will not be set aside unless for good cause. The Rules of Court mandate parties in a criminal case to stipulate facts to expedite trial. Once validly entered into, stipulations are conclusive and can only be relieved upon a showing of collusion, duress, fraud, misrepresentation, or undue influence, or for sufficient cause on terms that serve justice. The power to relieve a party lies in the court’s sound discretion. In this case, petitioners did not allege that the stipulations were false or obtained through force or fraud. Their claim of their former counsel’s alleged incompetence constituted a mistake of fact due to lack of diligence, which is not a ground for relief. Parties are bound by the acts, including mistakes and simple negligence, of their counsel. The constitutional presumption of innocence is not violated by stipulations, as an accused may knowingly admit facts as part of trial strategy. The Sandiganbayan did not commit grave abuse of discretion in denying the withdrawal.