Case Digest (G.R. No. 123792)
Facts:
Miriam Defensor Santiago v. Sandiganbayan, First Division, and People of the Philippines, G.R. No. 123792, March 08, 1999, Supreme Court First Division, Pardo, J., writing for the Court.
Petitioner Miriam Defensor Santiago was charged by Special Prosecution Officer Gualberto J. de la Llana before the Sandiganbayan, First Division by an Information filed May 13, 1991, for violation of R.A. No. 3019, Sec. 3(e) for allegedly approving applications for legalization of certain aliens in October 1988 contrary to Executive Order No. 324. An amended information was filed May 19, 1994, naming specific alien beneficiaries. At arraignment on June 27, 1994, petitioner pleaded not guilty.
The Sandiganbayan set a pre-trial for August 29, 1994 and later required the parties to advise by October 10, 1994 whether they intended to present testimonial evidence. On January 7, 1995 the parties filed a stipulation of facts which (inter alia) acknowledged the terms of Executive Order No. 324, recited that, except for two named aliens, the persons in the information entered the Philippines after January 1, 1984, and stated that the "main issue" was whether petitioner had the right to waive a specified EO 324 requirement; the stipulation framed the controversy principally as a legal question.
On January 30, 1995 the parties filed supplemental stipulations and agreed to file formal offers of documentary evidence and memoranda; the Sandiganbayan on January 31, 1995 gave deadlines for the formal offers and memoranda and declared the case to be deemed submitted thereafter. On May 25, 1995 the prosecution filed a Manifestation and Motion to reopen the case to allow the presentation of witnesses "to bring the case to its proper perspective" in light of admitted exhibits. Petitioner opposed on June 19, 1995, arguing the prosecution had rested, the issues were legal, the exhibits were self-evident public documents, and testimonial evidence would be immaterial.
Respondent Sandiganbayan issued a resolution dated August 3, 1995 ordering the reopening of the case to allow testimony of complainant Rodolfo Pedellaga to show "evident bad faith and manifest partiality." A motion for reconsideration was filed (dated in the record as Augu...(Subscriber-Only)
Issues:
- Did the Sandiganbayan commit grave abuse of discretion amounting to lack or excess of jurisdiction by reopening Criminal Case No. 16698 after the parties had stipulated facts, formally offered documentary evidence, and the case was deemed submitted, without affording petitioner an opportunity to rebut the proposed testimony?
- Was the proposed testimony of complainant Rodolfo Pedellaga material or pertinent to the parties’ agreed issues suc...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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