G.R. No. 143689-91 - Bayas vs. Sandiganbayan

Petitioners Sixto M. Bayas and Ernesto T. Matuday were charged before the Sandiganbayan (SBN) with violation of Section 3(e) of RA No. 3019 (Anti-Graft and Corrupt Practices Act), and two counts of malversation through falsification under Articles 217 and 171 of the Revised Penal Code.
Both were public officials of the Municipality of Kabayan, Benguet—Matuday as Municipal Mayor and Bayas as Municipal Treasurer.
The Informations were filed on May 6, 1999. During arraignment on September 21, 1999, the accused pleaded not guilty.

The pretrial conference initially scheduled on October 15, 1999, was cancelled due to the accused’s counsel, Atty. Jose M. Molintas, being unprepared; it was reset to November 5, 1999.
The November 5, 1999 pretrial was also cancelled for Atty. Molintas’s absence due to illness. However, the court encouraged the parties to discuss a drafted stipulation of facts for expeditious resolution at the next pretrial.
On December 10, 1999, the parties submitted a Joint Stipulation of Facts and Documents, signed by the accused, their counsel Molintas, and the prosecution’s Ombudsman Prosecutor Evelyn T. Lucero.

Accused Matuday was Municipal Mayor; Bayas was Municipal Treasurer and designated Municipal Accountant during the relevant periods.
Both accused admitted the disbursement of amounts P510,000.00 and P55,000.00.

Several exhibits were stipulated as evidence, including COA reports, memoranda, resolutions, disbursement vouchers, checks, journal entries, transcripts of Sangguniang Bayan sessions, investigation results, and relevant signatures.

The Defense agreed to present at least four witnesses; the Prosecution opted not to present any witnesses, relying on the stipulations.

The January 14, 2000 pretrial was again postponed due to absence of counsel Molintas; rescheduled to March 31, 2000 after his withdrawal on February 7, 2000.
On April 26, 2000, new counsel Atty. Cecilia M. Cinco moved to withdraw parts of the Joint Stipulation, specifically the admission of the disbursement amounts and related exhibits, invoking petitioners’ constitutional presumption of innocence.

On April 28, 2000, the SBN denied the Motion to Withdraw the Joint Stipulation, holding that stipulations made freely and voluntarily could not be withdrawn merely because the accused might be disadvantaged.
On May 26, 2000, the SBN denied petitioners’ motion for reconsideration, reiterating that the stipulation did not violate their constitutional rights and held that admissions will be used as provided by the Rules on Evidence.

Petitioners filed a Petition for Certiorari under Rule 65 before the Supreme Court praying to set aside these Orders.

Whether the Sandiganbayan committed grave abuse of discretion in denying the Motion to Withdraw the Joint Stipulation of Facts and Documents.
Whether the denial of withdrawal results in manifest injustice and impairs the constitutional rights of the petitioners, specifically the right to presumption of innocence, avoidance of self-incrimination, and due process.
Whether there exists any law or rule barring petitioners from withdrawing the Joint Stipulation of Facts and Documents unilaterally.