G.R. No. L-48302 November 23, 1988
ARTURO DEL POZO, DOMINADOR B. BORJE, EUGENIO LAMBIQUIT and JUAN LAMBIQUIT, petitioners, vs. HON. ALFONSO PENACO, City Judge, Branch 1, Ozamiz City, respondent.

FACTS

Petitioners were accused of falsification of a public document. The trial proceeded until the prosecution rested and the defense had presented eight witnesses. On March 27, 1978, the scheduled continuation, petitioners moved for deferment pending resolution by the Supreme Court of a petition for the inhibition of respondent Judge Penaco, which they had filed by registered mail that same day. Judge Penaco denied the motion, branding it a dilatory tactic, and declared the case submitted for decision due to the “conspicuous absence of the accused,” despite claims of improper notice and the alleged presence of one accused. He subsequently promulgated a judgment of conviction on April 5, 1978. Petitioners’ motions for reconsideration and new trial were denied. They then filed this special civil action for certiorari, arguing denial of due process.

ISSUE

Whether petitioners were denied due process when the trial court declared the case submitted for decision and convicted them without allowing them to complete the presentation of their defense evidence due to their motion for postponement anchored on a pending inhibition petition.

RULING

Yes, petitioners were denied due process. The Supreme Court granted the petition, annulled the judgment of conviction, and ordered a new trial. The legal logic is anchored on the fundamental right to be heard. While a judge has discretion to control the trial and prevent dilatory tactics, this discretion must be exercised judiciously to safeguard constitutional rights. Here, the postponement was sought based on a substantive plea for inhibition filed with the Supreme Court, which was a legitimate recourse questioning the judge’s impartiality. Declaring the case submitted for decision at that juncture was premature and arbitrary. The right to present evidence is a core component of due process. By cutting off the defense and proceeding to judgment while the inhibition issue was pending, the respondent judge effectively deprived petitioners of their day in court. The subsequent Supreme Court resolution, which partially granted the inhibition petition in a related case, underscored the legitimacy of the petitioners’ concerns. The haste in rendering judgment, under these specific circumstances, constituted a grave abuse of discretion equivalent to lack of jurisdiction. The proper course was to resolve the motion for postponement on its merits, considering the pendency of the higher court action, or at the very least, to await its resolution before proceeding, to ensure the fairness of the trial and the integrity of its outcome.