Case Digest (G.R. No. L-60613-20)
Facts:
Rolando Mangubat, et al. v. The Sandiganbayan, The People of the Philippines, and Delia Preagido, G.R. No. 60613-20, August 29, 1986, the Supreme Court En Banc, Narvasa, J., writing for the Court. Petitioners are several co-accused (listed) who sought relief against a Sandiganbayan resolution discharging one accused, Delia Preagido, to be used as a state witness under Section 9, Rule 119 of the Rules of Court.
The antecedent events began in several Sandiganbayan criminal cases (Nos. 889, 927, 1052, 1116, 1540 and 1582) when the prosecution moved to discharge three of the accused so they could be utilized as state witnesses under Section 9, Rule 119. Some co-defendants opposed the motion only as to Delia Preagido, asserting she had already been convicted by the Sandiganbayan in other cases of 126 counts of estafa and falsification of public/commercial documents, although she had seasonably appealed those convictions to the Supreme Court.
On March 5, 1982 the Sandiganbayan overruled the opposition and ordered Preagido and the two others discharged to become state witnesses, explaining that because Preagido’s convictions were still on appeal she remained cloaked with the constitutional presumption of innocence until a final conviction was promulgated. After discharge the Sandiganbayan received Preagido’s direct testimony for the prosecution over defense objection; cross-examination was deferred to allow the objecting defendants an opportunity to raise the Sandiganbayan’s action before the Supreme Court.
Petitioners filed a petition for certiorari (seeking nullification of the Sandiganbayan resolution as grave abuse of discretion). The Supreme Court initially denied relief in a decision promulgated April 20, 1985. Subsequently, petitioners sought reconsideration of that denial. Meanwhile, Preagido’s appeal from her prior convictions was finally resolved adversely to her by this Court on November 12, 1985 (entry of judgment November 21, 1985), a date occurring after the April 20, 1985 dismissal b...(Subscriber-Only)
Issues:
- Did the Sandiganbayan commit grave abuse of discretion warranting certiorari when it ordered the discharge of Delia Preagido as a state witness under Section 9, Rule 119 despite her prior convictions being on appeal?
- Does the subsequent final conviction of Delia Preagido (after her discharge and testimony) undo the discharge, permit her reinclusion as an accused, or render her testimony incompetent or inadmissible against her co-accused?
- If the Sandiganbayan’s discharge was erroneous, does that error necessit...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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