Facts:

• The case "Merciales v. Court of Appeals" (G.R. No. 124171) was decided on March 18, 2002, by the Supreme Court of the Philippines, with Justice Ynares-Santiago as the ponente.
• Petitioner Leticia R. Merciales is the mother of Maritess Ricafort Merciales, the victim in Criminal Cases Nos. 6307-6312 for rape with homicide.
• The cases were filed against private respondents Joselito Nuada, Pat. Edwin Moral, Adonis Nieves, Ernesto Lobete, Domil Grageda, and Ramon "Pol" Flores before the Regional Trial Court (RTC) of Legazpi City, Branch 8.
• During the trial, the public prosecutor filed a motion to discharge accused Joselito Nuada to be a state witness, which was denied by the trial court for failure to present evidence as required by Section 9, Rule 119 of the 1985 Rules on Criminal Procedure.
• The prosecution then filed a petition for certiorari with the Supreme Court, which did not issue a temporary restraining order.
• The trial court proceeded with the hearing, and the public prosecutor, instead of presenting further evidence, rested the case.
• Consequently, the trial court granted the demurrer to evidence filed by the accused and acquitted them.
• Petitioner Leticia Merciales sought to annul this order before the Court of Appeals, which dismissed her petition.
• The Supreme Court was then petitioned to reverse the decision of the Court of Appeals.

Issue:

• (Unlock)

Ruling:

1. Yes, the trial court and the public prosecutor violated due process.
2. No, the reopening of the criminal case does not violat...(Unlock)

Ratio:

• The Supreme Court found that the public prosecutor was guilty of serious nonfeasance by failing to present an available witness, thereby allowing the court to declare that the prosecution had rested its case.
• This failure violated Rule 119, Section 9 (now Section 17) of the Rules of Court, which requires the presentation of evidence in support of the prosecution's prayer for the discharge of an accused to be a state ...continue reading