Case Digest (G.R. No. 143689-91)
Facts:
Petitioners Sixto M. Bayas and Ernesto T. Matuday were charged before the Sandiganbayan for violation of Section 3(e) of RA No. 3019, as amended, and malversation through falsification in Criminal Case Nos. 25280-82 in relation to their positions as municipal treasurer and municipal mayor of Kabayan, Benguet. At arraignment, they pleaded not guilty, and a Joint Stipulation of Facts and Documents was submitted and signed on December 10, 1999 by the accused, their counsel, and the prosecution.
Before trial, petitioners’ counsel withdrew due to absence, and with new counsel (Atty. Cecilia M. Cinco) they moved on April 26, 2000 to withdraw portions of the joint stipulation, invoking constitutional rights; the Sandiganbayan denied the motion and reconsideration, prompting this Rule 65 petition.
Issues:
- May an accused unilaterally withdraw a joint stipulation of facts and documents signed with counsel during pre-trial before trial commences?
- Would denial of withdrawal result in manifest injustice or violate the accused’s constitutional rights?
- Is there any rule that bars an accused from withdrawing such stipulations?
Ruling:
The petition was denied. The Court held that stipulations freely and voluntarily made, and signed by the accused and counsel during pre-trial, are valid and binding and may not be set aside on the mere pretext that they may disadvantage the accused during trial.
The Court further ruled that the requested withdrawal was not justified absent a showing of grounds such as fraud, duress, collusion, misrepresentation, or sufficient cause; it found no grave abuse of discretion on the part of the Sandiganbayan and affirmed its assailed orders.
Ratio:
The Court emphasized that under the Rules on Criminal Procedure, parties are required to stipulate on matters of facts, issues, and evidence, and once such stipulations are validly entered into, they stand and function as binding judicial admissions, unless vitiated by recognized causes.
It rejected petitioners’ constitutional arguments, holding that the waiver inherent in stipulating facts—voluntarily and with counsel—does not impair the presumption of innocence, due process, or the right against self-incrimination; the Court also attributed the Sandiganbayan’s timing in acting on the stipulation to counsel’s earlier absence.
Doctrine:
- Pre-trial stipulations of facts and documents signed by the accused and counsel are valid and binding and cannot be withdrawn unilaterally absent good cause such as fraud, duress, collusion, misrepresentation as to facts, undue influence, or other sufficient justification.
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