G.R. No. 159275; August 25, 2010
Republic of the Philippines, Petitioner, vs. The Hon. Sandiganbayan (Second Division), Ricardo C. Silverio, Ferdinand E. Marcos (now substituted by his heirs), Imelda R. Marcos and Pablo P. Carlos, Jr. (now substituted by his heirs), Respondents.

FACTS

The Republic, through the PCGG, filed a case for reconveyance and recovery of ill-gotten wealth against respondents. After presenting only two witnesses and formally offering a limited set of documentary exhibits, the Republic rested its case. The Sandiganbayan admitted only one exhibit (Exhibit “A,” a Supreme Court Resolution) and denied admission of the other key documents (Exhibits “B” to “E”) for being mere photocopies, lacking authentication, and being irrelevant. The court later denied the Republic’s motion for reconsideration.
Subsequently, the Republic filed a motion to reopen the case for the purpose of presenting additional evidence, specifically to introduce the original or authenticated copies of the previously excluded exhibits and to present a new witness, a handwriting expert, to authenticate the signatures on the documents. The Sandiganbayan denied this motion, prompting the Republic to file the instant petition for certiorari.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction in denying the Republic’s motion to reopen the case for presentation of additional evidence.

RULING

The Supreme Court denied the petition, ruling that the Sandiganbayan did not commit grave abuse of discretion. The Court explained that a motion to reopen is not a matter of right but lies within the sound discretion of the trial court. This discretion must be exercised wisely and prudently, with due regard for the demands of justice and fairness to both parties.
The Court found no abuse in the denial. The Republic had already rested its case, and its belated attempt to present new evidence after its initial evidence was excluded demonstrated a lack of diligence. The Republic failed to justify why it did not secure the original documents or present the handwriting expert during its initial presentation of evidence. The Sandiganbayan correctly considered that granting the motion would cause undue delay and prejudice to the respondents, who have a right to the speedy disposition of the case. The Court emphasized that certiorari is not a remedy for errors of judgment but only for jurisdictional errors. The Sandiganbayan’s denial was a proper exercise of its discretionary power to control the proceedings and prevent delay, not a capricious or whimsical act constituting grave abuse of discretion.