Case Digest (G.R. No. 188881)
Facts:
In Republic of the Philippines v. Sandiganbayan (G.R. No. 188881, April 21, 2014), the Presidential Commission on Good Government (PCGG) as petitioner filed Civil Case No. 0008 in the Sandiganbayan twenty-four years earlier against Bienvenido R. Tantoco, Jr., Dominador R. Santiago, Ferdinand E. Marcos, Imelda R. Marcos, Bienvenido R. Tantoco, Sr., Gliceria R. Tantoco, and Maria Lourdes Tantoco-Pineda for reconveyance, reversion, accounting, restitution and damages. Rather than answer, respondents sought to strike complaint portions and obtain a bill of particulars—both denied—and then moved for production and inspection of documents under Rule 27. The graft court granted discovery; on November 21, 1991, the Supreme Court denied certiorari in Republic v. Sandiganbayan, affirming that discovery was essential. During pre-trial (January–July 1993), the PCGG produced Exhibits A–LLL. After pre-trial closed (September 10, 1996), the PCGG caused additional documents, Exhibits MMM–AAAAAA...Case Digest (G.R. No. 188881)
Facts:
- Proceedings below
- On May 13, 2009, the Republic of the Philippines (through the PCGG) filed a Petition for Certiorari under Rule 65 to annul the Sandiganbayan’s June 3, 2009 Resolution in Civil Case No. 0008.
- The assailed Resolution denied admission of documentary Exhibits MMM to AAAAAAAA offered in the Republic’s Formal Offer of Evidence.
- Underlying civil case
- In 1985, the PCGG filed Civil Case No. 0008 against Ferdinand and Imelda Marcos and the Tantocos for reconveyance, reversion, accounting, restitution, and damages.
- Instead of answering, respondents Tantoco Jr. and Santiago moved to strike portions of the complaint and for bill of particulars—both denied.
- Discovery and pre-trial
- July 1989 – respondents filed interrogatories; August 3, 1989 – Sandiganbayan granted motion for production and inspection of documents.
- November 21, 1991 – Supreme Court (in G.R. No. 90478) affirmed that order; pre-trial ensued.
- January 3 to July 14, 1993 – PCGG produced and preliminarily marked Exhibits A to LLL.
- September 10, 1996 – pre-trial closed; PCGG then pre-marked additional documents (MMM to AAA… up to AAAAAAAA).
- Motions on discovery non-compliance
- February 17, 1997 – respondents moved under Rule 29 to strike unproduced exhibits and cite PCGG for contempt; First Resolution denied contempt sanction.
- May 29, 2002 – respondents’ motion to ban introduction of exhibits not marked in discovery was denied.
- Formal Offer of Evidence and rulings on exhibits
- March 16, 2007 – Republic filed Formal Offer of Evidence, describing Exhibits MMM to AAAAAAAA, consisting of memoranda, letters, contracts, bank records, affidavits, invoices, royalty-bank documents, and microfilm.
- January 15, 2008 – Sandiganbayan denied admission of all exhibits for lack of showing due execution, authenticity, and for being mere photocopies.
- September 25, 2008 – on reconsideration, the court partly admitted some exhibits but retained Exhibits MMM to AAAAAAAA in limbo (“admitted liberally”).
- June 3, 2009 – on respondents’ motion, the Sandiganbayan finally excluded Exhibits MMM to AAAAAAAA as a sanction for non-production at discovery and for failing to authenticate originals.
- Supreme Court petition
- The Republic questioned only whether the Sandiganbayan gravely abused its discretion in excluding Exhibits MMM to AAAAAAAA due to the PCGG’s failure to produce them at pre-trial.
Issues:
- Whether the Sandiganbayan gravely abused its discretion in excluding Exhibits MMM to AAAAAAAA from evidence, on the ground of the Republic’s failure to produce them during discovery.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)