G.R. No. L-8611 - Justo vs. Court of Appeals

On April 4, 2005, the Deputy Ombudsman for Luzon issued a Resolution finding probable cause to indict respondents Leila L. Ang, Rosalinda Driz, Joey Ang, Anson Ang, and Vladimir Nieto:

Leila Ang for Falsification of Public Documents (Criminal Case No. 2005-1046)
All respondents for Malversation of Public Funds under Article 217, RPC (Criminal Case No. 2005-1047)
All respondents for Violation of Section 3(e), RA 3019 (Criminal Case No. 2005-1048)

The charges stemmed from a DBP special audit which uncovered alleged P4,840,884.00 cash shortages and fictitious journal entries to conceal the shortage.

On November 10, 2005, three Informations were filed with the RTC-Lucena, Branch 53.
On December 29, 2009, Ang filed an Amended Request for Admission in Criminal Case No. 2005-1048.
The Office of the City Prosecutor moved to expunge the Request, arguing such matters belong to pre-trial stipulations and evidence should be tested at trial.
On April 13, 2010, RTC-Branch 53 denied the Request and ordered its expunction.

Upon Judge Obnamia’s inhibition, cases were transferred to Judge Dennis R. Pastrana, Branch 56.
In the Joint Order dated February 12, 2015, Judge Pastrana granted Ang’s motion for partial reconsideration, deeming the People’s failure to respond as implied admissions under Section 2, Rule 26, and declared these “judicial admissions” under Rule 129.
The People’s Motion for Clarification was denied on July 24, 2015 for lateness; Judge Pastrana reaffirmed the implied and judicial admissions and ruled service through the City Prosecutor was sufficient.

Ang and the other respondents filed Manifestations adopting the implied/judicial admissions in Criminal Case No. 2005-1048 as their own in Cases No. 2005-1046 and No. 2005-1047.
On May 16, 2016, the RTC granted consolidation of the three criminal cases for joint trial.
In the Joint Order dated March 10, 2016, the RTC denied the People’s subsequent Requests for Admission, held the People’s prior admissions were binding and refused to vary or contradict them.
The People’s Motion for Reconsideration was denied on September 5, 2016; the RTC ruled that in consolidated cases, evidence in each case becomes evidence of all.

The People filed a Petition for Certiorari under Rule 65 before the Sandiganbayan assailing the RTC’s Joint Orders of March 10 and September 5, 2016.
On March 1, 2017, the Sandiganbayan dismissed the petition for lack of merit; a Motion for Reconsideration was denied on May 15, 2017.

The People filed a Petition for Review on Certiorari under Rule 45, raising errors regarding:

The Supreme Court took cognizance of two principal issues: the applicability of Rule 26 in criminal proceedings and the authority of the special prosecutor.

Applicability of Rule 26 (Requests for Admission) of the Rules of Court in criminal proceedings
Authority of the deputized special prosecutor to represent the People before the Sandiganbayan
(Subsidiary) Effect of consolidation on admissions and sufficiency of service of Requests for Admission