Title
Alegre vs. Reyes
Case
G.R. No. 56923
Decision Date
May 9, 1988
Petitioner charged with malversation sought to reopen trial to present evidence; Supreme Court ruled denial of motion was abuse of discretion, ordered reopening.
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Case Digest (G.R. No. 56923)

Facts:

1. Background of the Case:

  • Ramon J. Alegre, the petitioner, was charged with malversation of public funds under Article 217 of the Revised Penal Code.
  • The case was filed in the Court of First Instance of Manila, alleging that Alegre, as President and General Manager of the Philippine Jai-Alai & Amusement Corporation (PJAC), approved petty cash vouchers for payments and reimbursements totaling P18,170.00, which were charged against public funds held in trust for charitable purposes.

2. Trial Proceedings:

  • The trial commenced on November 17, 1977, and lasted for about two and a half years, with the prosecution presenting 29 witnesses and numerous exhibits.
  • Alegre, on the other hand, presented only his testimony and a few exhibits during two trial settings in September 1980.
  • After both parties submitted their memoranda, Alegre filed a "Motion to Reopen Trial for Presentation of Additional Evidence" on February 12, 1981, seeking to prove that the funds in question were not public and that he was not a public officer.

3. Motion to Reopen:

  • Alegre's motion specified several matters he intended to address with additional evidence, including the nature of the funds, the validity of certain resolutions, and refutations of specific portions of the NBI Report and affidavits presented by the prosecution.
  • The prosecution opposed the motion, arguing that the additional evidence would not affect the essential question of guilt or innocence and that Alegre had ample opportunity to present his evidence.

4. Trial Court's Denial:

  • The Trial Court denied Alegre's motion on February 26, 1981, stating that the accused had been given ample opportunity to present his evidence and that further evidence would be cumulative and superfluous.

5. Appeal to the Court of Appeals:

  • Alegre filed a petition for certiorari with the Court of Appeals, which dismissed the petition for lack of merit on April 28, 1981.

6. Supreme Court Petition:

  • Alegre then filed a petition for review on certiorari with the Supreme Court, seeking to reverse the decisions of the Court of Appeals and the Trial Court.

Issue:

  1. Whether the Trial Court committed grave abuse of discretion in denying Alegre's motion to reopen the trial for the presentation of additional evidence.
  2. Whether the Court of Appeals erred in dismissing Alegre's petition for certiorari.

Ruling:

The Supreme Court ruled in favor of Alegre, reversing the Decision of the Court of Appeals and the Order of the Trial Court. The Court held that the Trial Court acted unreasonably and capriciously in denying Alegre's motion to reopen the trial. The respondent Judge was ordered to reopen the case for the reception of Alegre's additional evidence.

Ratio:

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