Case Digest (G.R. No. 143439)
Facts:
In Criminal Case No. 19933-MN for arson, the People of the Philippines, represented by the complaining witness Susan Ramirez, charged Maximo Alvarez with setting fire to Ramirez’s house in Dagat-dagatan, Navotas, on May 29, 1998. The accused was married to Esperanza G. Alvarez, sister of Susan Ramirez. On June 21, 1999, the prosecution called Esperanza as its first witness; she identified her husband as the person who poured gasoline and ignited the door of Ramirez’s house. During her direct examination, the trial judge noted the accused’s “uncontrolled emotions” and suspended proceedings. On June 30, 1999, Alvarez, through counsel, moved to disqualify Esperanza under Rule 130, Section 22 of the Revised Rules of Court (the marital disqualification rule). The trial court, Branch 72, RTC Malabon City, granted the motion on September 2, 1999 and struck out her testimony; a motion for reconsideration was denied on October 19, 1999. Susan Ramirez then petitioned the Court of Appeals ...Case Digest (G.R. No. 143439)
Facts:
- Parties and Case Background
- Petitioner Maximo Alvarez is accused in Criminal Case No. 19933-MN for arson, alleged to have poured gasoline and set fire to the house of his sister-in-law, Susan Ramirez.
- Respondent Susan Ramirez is the private prosecutor and owner of the burned house; Esperanza G. Alvarez is both petitioner’s wife and respondent’s sister.
- Trial Court Proceedings
- On June 21, 1999, the prosecution called Esperanza Alvarez as its first witness; she identified petitioner as the man who poured gasoline and ignited the fire.
- Petitioner’s counsel raised no immediate objection; proceedings were suspended briefly when petitioner displayed “uncontrolled emotions.”
- Motion to Disqualify and Trial Court Orders
- On June 30, 1999, petitioner moved to disqualify Esperanza under Rule 130, Sec. 22 (marital disqualification), which respondent opposed.
- On September 2, 1999, the RTC disqualified Esperanza from further testimony and struck her prior testimony; a motion for reconsideration was denied on October 19, 1999.
- Appellate and Supreme Court Review
- Susan Ramirez filed a petition for certiorari with the Court of Appeals, which on May 31, 2000 nullified and set aside the RTC’s disqualification orders.
- Petitioner sought review on certiorari before the Supreme Court, challenging the CA decision.
Issues:
- Applicability of the Marital Disqualification Rule
- Whether, under Rule 130, Sec. 22, Esperanza Alvarez is disqualified from testifying against her husband during their marriage without his consent.
- Whether that rule applies in a criminal case for a crime allegedly committed by one spouse against the other.
- Exception to Marital Disqualification
- Whether the offense of arson directly and vitally impairs the conjugal relationship, thus invoking the statutory exception.
- Whether the de facto separation and strain in the marital relationship eliminate the policy reasons for disqualification.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)