Title
Republic vs. Sandiganbayan
Case
G.R. No. 188881
Decision Date
Apr 21, 2014
The Supreme Court upheld the Sandiganbayan's exclusion of documents for failure to comply with discovery orders and establish authenticity.
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Case Digest (G.R. No. 188881)

Facts:

  • The Republic of the Philippines is the petitioner against several respondents, including Bienvenido R. Tantoco, Jr., Dominador R. Santiago, Ferdinand E. Marcos, Imelda Marcos, Bienvenido R. Tantoco, Sr., Gliceria R. Tantoco, and Maria Lourdes Tantoco-Pineda.
  • The petition was filed on April 21, 2014, regarding a resolution from the Sandiganbayan dated June 3, 2009, in Civil Case No. 0008.
  • The Republic, through the Presidential Commission on Good Government (PCGG), initiated a complaint for reconveyance, reversion, accounting, restitution, and damages, alleging involvement in ill-gotten wealth during the Marcos regime.
  • Respondents filed a motion to strike portions of the complaint and requested a bill of particulars, which the Sandiganbayan denied.
  • The respondents later filed interrogatories and a motion for document production, which were granted.
  • The PCGG produced several documents during the pre-trial phase, marked as Exhibits Aa to LLL.
  • Additional documents, marked as Exhibits MMM to AAAAAAAA, were produced later, leading to objections from the respondents.
  • The Sandiganbayan denied the admission of these additional exhibits, citing failure to show due execution and authenticity.
  • The Republic's motion for reconsideration resulted in partial admission of some exhibits but ultimately excluded Exhibits MMM to AAAAAAAA.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied the petition for certiorari, affirming the Sandiganbayan's resolution that exclude...(Unlock)

Ratio:

  • The Supreme Court determined that the Sandiganbayan did not exhibit grave abuse of discretion in excluding the documents.
  • The Court highlighted that trial courts have discretion over evidence admission, which should not be interfered with unless there is clear evidence of grave abuse.
  • The Republic's failure...continue reading

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