Case Digest (G.R. No. L-10971)
Facts:
The People of the Philippines, through Jesus Quintillan, etc., petitioners, vs. Urbano Jaca, et al., G.R. No. L-10971. November 28, 1959, the Supreme Court En Banc, Paras, C.J., writing for the Court.The prosecution charged respondents Urbano Jaca, Bonifacio Jaca and Go Bian Ling with violating the Anti‑Dummy Law (Commonwealth Act No. 108, as amended) in relation to Sections 1 and 5 of Article XIII of the Constitution before the Court of First Instance of Davao (trial court). The information alleged that between July 30, 1949 and May 27, 1956 the accused Filipinos conspired with the alien respondent Go Bian Ling to permit an alien to intervene in the management and operation of a business developing and exploiting timberland, specifically by forming a partnership (capitalized at P16,000) doing business as the Mindanao Hardwood Lumber Company, of which Go Bian Ling was alleged to be the manager, and by conveying the timber license to that partnership.
At the early stages of trial the prosecution sought to develop proof that the Mindanao Hardwood Lumber Company (also referred to in evidence as Victor Erickson and Company) manufactured lumber from respondent Urbano Jaca’s timber concession and sold products to a firm called Mindanao Commercial Company at prices below prevailing market rates. Witnesses called included Nicolas Santos, who gave evidence on prevailing lumber prices in Davao City during 1949–1950, and Fidel Reyes, who testified that Sta. Clara Lumber Company received logs from Mindanao Hardwood for its plywood operations between September 1952 and May 1955.
On direct examination the prosecutor asked Reyes: “Regarding the value of the logs delivered by a Mindanao Hardwood Lumber Company thru Mr. Go Bian Ling, did you look into the records of your office (Sta. Clara Lumber Company)?” The trial judge motu proprio rejected that question, stating that “the amount of the transactions is not necessarily to be proved further regarding this case.” Co‑accused also objected that the question tended to establish an offense not alleged in the information. Other prosecution questions aimed at showing that payments for logs went to Mindanao Commercial Company (allegedly indicating a dummy arrangement)...(Pro-only)
Issues:
- Did the trial court commit error in excluding the prosecution’s question to Fidel Reyes and related evidence at the preliminary stage of the trial?
- Was the excluded evidence relevant to proving that an alien intervened in the management and operation of the timber business in violation of C.A. No. 108, Sec. 2‑A(3) (in relation to Sections 1 and 5, Art...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)