Facts:

The case involves the Republic of the Philippines as 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, concerning a resolution issued by the Sandiganbayan on 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 against the respondents, alleging that they were involved in the accumulation of ill-gotten wealth during the Marcos regime.

The legal proceedings began when the respondents filed a motion to strike out portions of the complaint and requested a bill of particulars, which the Sandiganbayan denied. Subsequently, the respondents filed interrogatories and a motion for the production and inspection of documents,...

Facts:

Background of the Case

1. Initiation of the Case: The Republic of the Philippines, through the Presidential Commission on Good Government (PCGG), filed a complaint in 1989 for reconveyance, reversion, accounting, restitution, and damages against respondents, including Bienvenido R. Tantoco Jr., Dominador R. Santiago, Ferdinand E. Marcos, Imelda Marcos, and others.
2. Discovery Proceedings: Respondents filed a Motion for Production and Inspection of Documents, which the Sandiganbayan granted, and the Supreme Court affirmed. The PCGG produced documents marked as Exhibits "A" to "LLL" during pre-trial.
3. Additional Documents: Later, the PCGG produced and marked additional documents, Exhibits "MMM" to "AAAAAAA," over the objections of respondents, who argued these were not disclosed during discovery.
4. Formal Offer of Evidence: The Republic formally offered these additional documents as evidence in 2007, but the Sandiganbayan initially denied their admission, citing lack of authentication and failure to present originals.
5. Partial Admission: Upon reconsideration, the Sandiganbayan admitted some exhibits but ultimately denied admission to Exhibits "MMM" to "AAAAAAA" in a 2009 resolution, citing the Republic’s failure to comply with discovery orders.

Issue:

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Ruling:

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Ratio:

1. Grave Abuse of Discretion: The Sandiganbayan’s decision was not arbitrary or whimsical. The Republic’s failure to comply with discovery orders and authenticate the documents justified the exclusion.
2. Discovery Sanctions: Under Rule 29 of the Rules of Court, sanctions, including the exclusion of evidence, are warranted for failure to comply with discovery orders. The Republic’s non-compliance was willful, warranting the imposition of sanctions.
3. Best Evidence Rule: The Sandiganbayan correctly applied the Best Evidence Rule. The Republic failed to present original documents or prove that the exceptions to the rule applied.
4. Authentication of Documents: Private documents must be authenticated under Section 20, Rule 132 of the Rules of Court. The Republic failed to authenticate the exhibits, rendering them inadmissible.
5. Public Documents: Public documents must be proved in accordance with Rule 132. The Republic failed to meet the requirements for proving public documents, such as providing certified true copies attested by the proper custodian.

Conclusion:

The Supreme Court upheld the Sandiganbayan’s exclusion of Exhibits "MMM" to "AAAAAAA," finding no grave abuse of discretion. The Republic’s failure to comply with discovery orders and authenticate the documents justified their exclusion.