Case Digest (G.R. No. 111682)
Facts:
- Zenaida Reyes is the petitioner against the Court of Appeals and the People of the Philippines.
- An information was filed on April 7, 1986, in the Regional Trial Court of Bulacan, Branch 22, as Criminal Case No. 9252-M.
- Reyes was accused of falsifying a deed of sale for four parcels of land by forging the signature of Pablo Floro, who was unable to sign due to age-related infirmities.
- Reyes pleaded not guilty upon arraignment, and the trial commenced.
- The prosecution rested its case, and the defense was set to present evidence on February 6, 1989, but this was postponed due to Reyes's illness.
- Subsequent hearings were canceled or postponed due to the absence of Reyes and her counsel, Atty. Analuz Cristal-Tenorio.
- On July 10, 1989, both Reyes and Atty. Tenorio were absent, leading the court to declare a waiver of Reyes's right to present evidence.
- Reyes submitted a medical certificate for her illness but was informed that the court's order stood.
- A motion for reconsideration was denied, and on September 29, 1989, Reyes was found guilty and sentenced.
- Reyes appealed the decision, but the Court of Appeals affirmed the ruling, prompting her to file a motion for reconsideration, claiming denial of due process.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the trial court's decision to consider Reyes as having waived her right to present evidence was improper.
- The Court found that Reyes was denied due process, as he...(Unlock)
Ratio:
- The Supreme Court emphasized that the right to present evidence is fundamental to due process.
- The repeated absences of Reyes's counsel were significant factors in the failure to present a defense.
- The trial court's discretion in granting postponements must be exercised judiciously, considering the circumstances of each case.
- Reyes's health issues explained her absences, while her counsel's unexplained absences indicated a lack of diligence affecting Reyes's ability ...continue reading
Case Digest (G.R. No. 111682)
Facts:
The case involves Zenaida Reyes as the petitioner against the Court of Appeals and the People of the Philippines as respondents. The events leading to this case began with an information filed on April 7, 1986, in the Regional Trial Court of Bulacan, specifically assigned to Branch 22 as Criminal Case No. 9252-M. Zenaida Reyes was accused of falsifying a deed of sale for four parcels of land by feigning the signature of Pablo Floro, who was unable to sign due to age-related infirmities. The prosecution alleged that Reyes caused it to appear that Floro participated in the execution of the document, which he did not. Upon arraignment, Reyes pleaded not guilty, and trial commenced.
The prosecution rested its case, and the defense was scheduled to present evidence on February 6, 1989. However, this was postponed to March 10, 1989, due to Reyes's illness. The hearing on March 10 was canceled due to the absence of both the private prosecutor and Reyes's counsel, Atty. Analuz Cristal-Tenorio. The next scheduled hearing was on April 12, 1989, but Atty. Tenorio was again absent, and Reyes was also absent, although her husband submitted a medical certificate indicating her illness. The court postponed the hearing to May 17, 1989.
On May 11, 1989, Atty. Tenorio requested another postponement to June 5, 1989, citing personal reasons. The trial court granted this request despite objections from the private prosecutor, warning Reyes that failure to present evidence on that date would be considered a waiver of her right to do so. However, on June 5, 1989, the hearing was rescheduled again due to Atty. Tenorio's absence. On July 10, 1989, both Reyes and Atty. Tenorio were absent, leading the court to declare that Reyes ha...