G.R. No. L-32052 - Philippine Virginia Tobacco Administration vs. Court of Industrial Relations

Petitioner Norberto Lee was employed as the New Account Service Representative, Manager’s Check and Gift Check Processor at the Cash Department of Allied Banking Corporation (Allied Bank).
Respondents include the People of the Philippines and Allied Bank.
The case was rendered by the Third Division in G.R. No. 192274, February 08, 2012.

Allied Bank alleged that Lee forged the signatures of its responsible officers on several manager’s checks, causing damage and prejudice to the bank.
After a preliminary investigation, Lee was charged with Estafa through Falsification of Commercial Documents, with charges consolidated in eight separate Informations.
The common elements of the Information stated that on or about May 20, 1999, Lee, using his position, allegedly falsified signatures on check instruments, misappropriated funds, and caused financial loss to Allied Bank.

During the trial, on February 12, 2007, Lee filed a Motion for Document and Handwriting Examination by the National Bureau of Investigation (NBI).

His motion argued that the preliminary investigation failed to include an examination of his questioned signature alongside those of the bank officers.
Lee contended that the PNP Crime Laboratory’s report was incomplete, biased, and prepared without his participation.

On August 22, 2007, the Regional Trial Court (RTC), Branch 143, Makati City, presided by Judge Tranquil P. Salvador, Jr., denied his motion.

The RTC reasoned that, since the trial was already ongoing, Lee could present the available NBI-intended witness during the presentation of defense evidence.
The court also emphasized its own duty to examine the disputed signatures independently.

Lee subsequently filed a Motion for Reconsideration on September 26, 2007—two days beyond the reglementary period—which was also denied by the RTC through Presiding Judge Zenaida T. Galapate-Laguilles.
The Court of Appeals (CA), in its October 26, 2009 decision, dismissed Lee’s petition for certiorari under Rule 65 and affirmed the RTC’s interlocutory orders.
Ultimately, Lee pursued a petition for review on certiorari under Rule 45 before the Supreme Court, challenging the RTC and CA decisions.

Lee contended that the denial of his motion for document and handwriting examination violated his constitutional right to due process and equal protection.
He argued that it was legally and practically impossible for him to secure an NBI witness without a compulsory judicial order.
Lee asserted that the RTC and CA committed grave abuse of discretion by not applying the traditional “doctrine of liberality” in interpreting procedural rules, thereby causing prejudice against him.
He also claimed that the interlocutory orders should be nullified as they were rendered with lack or excess of jurisdiction and with disregard of fair play and due process.

Whether the RTC and the Court of Appeals gravely erred in ignoring the traditional “doctrine of liberality” when applying the mechanical rules of procedure.
Whether petitioner Norberto Lee was legally entitled to a new and credible NBI document and handwriting examination of the relevant and material documents with full participation, as part of his constitutional right to due process and equal protection.
Whether the RTC and CA committed grave error in denying Lee’s motions for a document and handwriting examination—first the initial motion and subsequently the motion for reconsideration filed late.
Whether the interlocutory orders, having attained “finality,” should be treated akin to a “final and executory judgment” despite being of an interlocutory nature.