G.R. No. 158275 - Roco vs. Contreras

In 1993, petitioner Domingo Roco purchased dressed chicken from Calas Poultry Supply Corporation (“Calas Corporation”).
Petitioner issued five (5) checks to Calas Corporation, drawn on his closed Philippine Commercial and Industrial Bank (PCIB) account:

Calas Corporation deposited the checks; PCIB dishonored them for “closed account.”

Calas Corporation filed five criminal complaints under BP 22 before MTCC, Roxas City (Crim. Cases Nos. 94-2172-12 to 94-2176-12).
Petitioner filed a denunciation with BIR against Calas Corporation for alleged tax invoice violations; BIR found no evidence of tax evasion.
MTCC initially convicted petitioner; on appeal the RTC vacated and remanded for reception of petitioner’s evidence.

On remand, petitioner sought subpoenas ad testificandum and duces tecum for Calas officers (Vivian Deocampo or Danilo Yap) to produce accounting records (sales journals, ledgers, audited statements, balance sheets, tax returns for 1993–1999).
MTCC Branch 2 first granted the request (19 May 1999), then allowed prosecution’s opposition; on 19 October 1999, MTCC (Presiding Judge Edward B. Contreras) denied the request as immaterial and delaying.
MTCC denied reconsideration. Petitioner filed certiorari (SP No. V-7489) with RTC, which dismissed for lack of grave abuse of discretion (18 October 2000), and denied his motion for reconsideration.

Petitioner appealed via Rule 45 to the Court of Appeals (CA-G.R. SP No. 66038); CA dismissed petition (20 August 2002) and denied reconsideration (12 May 2003).
Petitioner brought the case to the Supreme Court, challenging the denial of subpoenas and alleging infringement of his constitutional right to present evidence and the right to speedy disposition of cases.

Whether the courts below committed reversible error in denying petitioner’s request for subpoenas ad testificandum and duces tecum.
Whether the denial violated petitioner’s constitutional right to present evidence (Art. III, §14(2), Constitution) and to a speedy disposition of his case.