Case Digest (G.R. No. 173559) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Hubert Jeffrey P. Webb, G.R. No. 132577 decided on August 17, 1999, respondent Hubert Jeffrey P. Webb stood charged with Rape with Homicide (Criminal Case No. 95-404) before Branch 274 of the Regional Trial Court of Parañaque, presided by Judge Amelita G. Tolentino. On May 2, 1997, Webb filed a Motion to Take Testimony by Oral Deposition for five United States–based individuals—two U.S. Department of Justice officials, two California Department of Motor Vehicles employees, and a private resident—asserting that their material and indispensable testimony could not be compelled in Philippine courts. He sought to have their depositions taken before Philippine consular officers in Washington, D.C., and California under Sections 4 and 5 of Rule 119 and Section 4, Rule 24 of the Revised Rules of Court. The prosecution opposed, contending these provisions did not authorize depositions during trial or outside Philippine jurisdiction. The trial court denied Case Digest (G.R. No. 173559) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Charge
- The People of the Philippines (petitioner) filed Criminal Case No. 95-404 for Rape with Homicide against Hubert Jeffrey P. Webb (respondent), et al., before RTC Branch 274, Parañaque, presided by Judge Amelita G. Tolentino.
- Respondent Webb is one of the accused in the above-captioned criminal case.
- Motion to Take Oral Depositions
- On May 2, 1997, Webb moved to take the oral depositions of five U.S. residents—Steven Bucher, Debora Farmer, Jaci Alston, Ami Smalley, and John Pavlisin—before Philippine consular officers in Washington, D.C. and California.
- He alleged their testimonies were “material and indispensable” to his defense and that they could not be compelled to testify by subpoena under Philippine jurisdiction.
- Webb invoked Section 4, Rule 24, Revised Rules of Court, as authority for taking such depositions.
- Trial Court Rulings and Appeal to the Court of Appeals
- The prosecution opposed: (a) Rule 24, Section 4 does not apply to criminal cases; (b) Rule 119, Sections 4 and 5 limit conditional examinations to before trial and within Philippine territory.
- The RTC denied the motion on June 11, 1997, and likewise denied reconsideration on July 25, 1997.
- Webb petitioned for certiorari (CA-G.R. SP No. 45399); on February 6, 1998, the Court of Appeals annulled the RTC orders and granted Webb’s motion to take depositions.
- Supreme Court Proceedings
- The People elevated the case to the Supreme Court by petition for review on certiorari under Rule 45, challenging the CA’s application of civil deposition rules to criminal proceedings, allowance of depositions before consular officers, and alleged denial of due process.
- Respondent Webb filed an Answer (Comment), and the People filed a Reply.
- The petition was deemed ripe for decision.
Issues:
- Whether the trial court gravely abused its discretion in denying Webb’s motion to take oral depositions of five U.S.-based witnesses.
- Whether civil deposition rules (Rule 23/Rule 24) apply in criminal proceedings to permit depositions during trial.
- Whether depositions may be taken before Philippine consular officers abroad.
- Whether denying the deposition motion deprived Webb of due process and his right to present a complete defense.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)