Case Digest (G.R. No. 56923)
Facts:
The case involves Ramon J. Alegre as the petitioner against Hon. Manuel T. Reyes and the People of the Philippines as respondents. The events leading to this case began when Alegre was indicted in the Court of First Instance of Manila for malversation of public funds under Article 217 of the Revised Penal Code. The amended information alleged that between October 17, 1975, and April 30, 1976, Alegre, who was the President and General Manager of the Philippine Jai-Alai & Amusement Corporation (PJAC), unlawfully approved disbursements from public funds, which he was obligated to account for as a public officer. The prosecution claimed that Alegre's actions allowed others to misappropriate funds amounting to P18,700.80, which were intended for charitable purposes.
Alegre entered a plea of not guilty during his arraignment. The trial commenced on November 17, 1977, and lasted until March 24, 1980, during which the prosecution presented 29 witnesses and numerous exhibits...
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:
- Whether the Trial Court committed grave abuse of discretion in denying Alegre's motion to reopen the trial for the presentation of additional evidence.
- 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:
- (Unlock)