G.R. No. L-29836 - People vs. Domondon

An original action of certiorari, prohibition, and mandamus with a prayer for a preliminary injunction was filed by the People through State Prosecutor Alejandro C. Siazon of the Department of Justice.
The petition targets respondent Judge Sexto A. Domondon of the Court of First Instance of Pangasinan, San Carlos City (Pangasinan) Branch, and involves actions taken during the trial of criminal cases.
The criminal charges pertain to violations of the Anti-Graft and Corrupt Practices Act (Republic Act No. 3019) in connection with the alleged leakage of test questions for the Teachers’ Selective Examination held on June 18, 1966 in Lingayen, Pangasinan, and Tarlac.

The private respondents in Criminal Cases Nos. SCC-128, 129, and 130 are Filomena Gabriel, Jose C. Arenas, and Estela Macam-Nicanor, respectively.
A fourth information (Criminal Case No. SCC-131) was initially filed against Jessie S. Siapno but was dismissed on motion by the People to utilize her as a state witness.
At the time of the alleged commission of the crime, two defendants were private individuals while the conspiracy aspect involved the public school teachers and these private individuals.

Three of the defendants—Filomena Gabriel, Jose C. Arenas, and discharged defendant Jessie S. Siapno—executed sworn extrajudicial confessions. Estela Macam-Nicanor did not make an extrajudicial confession.
During the joint trial sessions on November 18 and 19, 1968, Jessie S. Siapno testified from the witness stand regarding her extrajudicial confession marked as Exhibit "V" (with sub-markings V-1 through V-6).

When asked to identify her signature on each page of Exhibit "V", an objection on the ground that it would incriminate her was raised by the defense.
The objection was sustained by respondent Judge after confirming that Siapno had been informed that her testimony could be used for an administrative case.

The case also involved a dispute regarding the proper admission of evidence concerning a test booklet:

Siapno’s extrajudicial confession mentioned that she purchased a test booklet from Estela Macam-Nicanor.
The defense objected to her identifying the booklet, invoking the best evidence rule.
Prosecution later presented page 8 of the test booklet (Exhibit "W") and had witness Minas Gabertan testify regarding its content.

Subsequent to the filing of the present petition, respondent Judge Domondon was transferred to the Mangaldan Branch, and another judge was appointed in San Carlos City Branch where the cases originated.
A supplemental petition alleged that Judge Domondon failed to turn over the records of Criminal Cases Nos. SCC-128 to 130 to the new presiding judge, thereby potentially compromising the orderly administration of justice.
The petitioner sought a declaration that these cases fall exclusively under the authority of the judge permanently appointed to the San Carlos City Branch and an order prohibiting Judge Domondon from continuing with the trials.

Whether the right against self-incrimination, as guaranteed by Section I (18), Article III of the Constitution, applies to witness Jessie S. Siapno during her testimony on the extrajudicial confession.
Whether the witness’s waiver of her right against self-incrimination is effective and sufficient in authorizing the questioning of her signature on Exhibit "V."

Whether the extrajudicial confession of discharged defendant Jessie S. Siapno is admissible as evidence in conjunction with other circumstantial evidences regarding the alleged criminal participation.
Whether the matching and identical material details among the confessions of the other defendants corroborate the testimony and render the confession admissible against the persons charged.

Whether discharged defendant Siapno should be allowed to describe the test booklet mentioned in her extrajudicial confession, notwithstanding the objection based on the best evidence rule.
Whether the recollection of testimony by a prosecution witness (Minas Gabertan) suffices to meet the requirements of the best evidence rule given that part of the test booklet had been burned.

Whether respondent Judge’s failure to turn over the records of Criminal Cases Nos. SCC-128 to 130 to the presiding judge of the San Carlos City Branch is proper and in conformity with orderly judicial administration.
Whether such failure calls for a prohibition against Judge Domondon from continuing the trial of the said cases.