GR 165996; (October, 2005) (Digest)
G.R. No. 165996 October 17, 2005
Rodolfo G. Valencia, Petitioner, vs. The Sandiganbayan, Respondent.
FACTS
Petitioner Rodolfo G. Valencia, then Governor of Oriental Mindoro, was charged before the Sandiganbayan with violation of Section 3(e) of R.A. 3019 (Anti-Graft and Corrupt Practices Act). The Information alleged that on December 1, 1992, within one year after the May 1992 elections, he appointed Cresente Umbao—a losing candidate in that election—as Sangguniang Bayan member, thereby giving unwarranted benefit and causing undue injury to the government. After pleading not guilty, the prosecution and defense submitted a Joint Stipulation of Facts during pre-trial. Based on this stipulation, the prosecution rested its case and waived the presentation of further evidence. Valencia, however, refused to sign the stipulation and filed a Motion for Leave to File Demurrer to Evidence, arguing the prosecution failed to establish the essential elements of the crime.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in denying petitioner’s motion for leave to file a demurrer to evidence and in recalling the pre-trial order to allow the prosecution to present evidence.
RULING
No. The Supreme Court held that the Sandiganbayan did not commit grave abuse of discretion. A demurrer to evidence is filed after the prosecution rests its case, challenging the sufficiency of the evidence presented. Here, the prosecution’s purported resting of its case was premised on the Joint Stipulation of Facts. However, since Valencia expressly repudiated and refused to sign the stipulation, it could not be considered as established judicial admissions binding upon him. Consequently, the Sandiganbayan correctly recalled its pre-trial order and ruled that the prosecution had not effectively rested its case, as no evidence had been formally offered and admitted. The court’s order to proceed with the presentation of prosecution evidence was a proper exercise of its discretion to ensure a full and fair trial based on competent evidence. The denial of leave to file a demurrer was therefore justified, as such a motion would be premature absent any validly admitted evidence for the prosecution. The petition for certiorari was dismissed for lack of merit.