Facts:

The case involves Avelino C. Agulto as the petitioner and the Hon. Court of Appeals, Hon. Francisco Z. Consolacion, and the People of the Philippines as respondents. The events leading to this case began on April 23, 1970, when an information for bigamy was filed against Agulto. The charge alleged that on December 30, 1968, in Davao City, Agulto, who was previously married to Maria Pilar Gaspar, contracted a second marriage with Andrea Suico while his first marriage was still valid and subsisting. After the trial concluded and both parties had rested their cases, Agulto filed a motion on November 12, 1975, to reopen the trial, claiming he had newly-discovered evidence in the form of a marriage contract between Andrea Suico and one Romeo Vergeire, which was supposedly executed on July 19, 1960, prior to Suico's marriage to Agulto. The trial court denied this motion on March 23, 1976, stating that Agulto could have discovered this evidence earlier, as he was aware of Suico&...

Facts:

Case Background:

• Petitioner Avelino C. Agulto was charged with bigamy in an information filed on April 23, 1970, for allegedly contracting a second marriage with Andrea Suico on December 30, 1968, while his first marriage to Maria Pilar Gaspar was still valid and subsisting.

Motion to Reopen Trial:

• After the trial was concluded and the parties had rested their case, but before judgment was rendered, Agulto filed a motion on November 12, 1975, to reopen the trial. He claimed to have newly-discovered evidence: a copy of a marriage contract between Andrea Suico and Romeo Vergeire dated July 19, 1960, which was allegedly contracted before Andrea’s marriage to him.

Trial Court’s Decision:

• On March 23, 1976, the trial court denied the motion, stating that it was filed too late. The court noted that Agulto had been aware of the alleged marriage between Andrea Suico and Romeo Vergeire as early as October 17, 1972, and could have discovered and presented this evidence earlier.

Certiorari Petition to the Court of Appeals:

• Agulto filed a petition for certiorari in the Court of Appeals, arguing that the trial court gravely abused its discretion in denying his motion to reopen the trial. He claimed the newly-discovered evidence would prove that his marriage to Andrea Suico was null and void due to her prior marriage to Romeo Vergeire.

Court of Appeals’ Decision:

• The Court of Appeals denied the petition, finding no grave abuse of discretion by the trial court. It also noted that the alleged marriage contract between Andrea Suico and Romeo Vergeire lacked authenticity, as it bore no seal, did not specify the location of the marriage, and appeared to have been conducted without a marriage license.

Issue:

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Ruling:

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Ratio:

1. Motion to Reopen Trial vs. Motion for New Trial:

   • A motion to reopen trial is distinct from a motion for new trial. It is a procedural recourse available after both parties have formally offered and closed their evidence but before judgment is rendered. It is not governed by specific rules but is subject to the sound discretion of the trial court, with the paramount interest of justice in mind.

2. Requirements for Newly-Discovered Evidence:

   • For a motion to reopen trial based on newly-discovered evidence, the evidence must be such that it could not have been discovered earlier despite due diligence. In this case, the petitioner was aware of the alleged prior marriage of Andrea Suico as early as 1972, yet failed to present the evidence during the trial.

3. Deficiencies in the Evidence:

   • The alleged marriage contract between Andrea Suico and Romeo Vergeire was deemed unreliable due to lack of authenticity, absence of a seal, and failure to specify the location of the marriage. Additionally, the document appeared to be based on a xerox copy and was not properly certified or authenticated.

4. Dilatory Nature of the Motion:

   • The Court found that the motion bore the earmarks of a dilatory pleading, as it succeeded in delaying the case for 14 years without substantial merit.

5. Significance of the Fiscal’s Decision:

   • The Court noted that the fiscal did not charge Andrea Suico with bigamy, suggesting that she was not under any legal impediment to contract a second marriage, further undermining the petitioner’s claim.