G.R. No. 134998 - Tiu vs. Middleton

The case arose from a Complaint for recovery of ownership and possession of real property, together with claims for accounting and damages, filed before the Regional Trial Court (RTC) of Oroquieta City.
The dispute pertained not only to property ownership but also to procedural issues concerning the admissibility of evidence at trial.

Prior to trial, the RTC sent a Notice of Pre-trial Conference which clearly warned that witnesses whose names and addresses were not submitted may be barred from testifying, and documents not marked as exhibits might likewise be excluded.
In his Pre-trial Brief, the petitioner stated his intention to present six witnesses by indicating that their direct testimonies would average one hour each.
Notably, although the petitioner mentioned the number of witnesses, he failed to provide their names and the synopses of their respective testimonies as required by the pre-trial rules.

Acknowledged that the petitioner would present six witnesses.
Specified the hearing dates for the presentation of evidence.
Made no explicit provision that the unnamed witnesses would be barred from testifying.

During trial, when the petitioner called Antonia Tiu (one of his intended witnesses) as his first witness, the respondents objected on the ground that her name and a synopsis of her testimony were not included in the pre-trial brief.
Citing Section 6, Rule 18 of the 1997 Rules of Civil Procedure and relying on prior jurisprudence, the trial court ultimately barred Antonia Tiu from testifying.
Subsequently, an order denying petitioner's request for reconsideration was also issued by the RTC, thereby reinforcing the bar on the unnamed witness.

Pre-trial requirements mandating the naming of witnesses do not authorize a judge to exclude a witness solely for being unnamed when the Pre-trial Order permitted his six witnesses.
There was no pre-trial order expressly stating that the failure to list witness names would result in their exclusion.
Procedural technicalities should not override the substantive due process rights of the parties.

The exclusion of Antonia Tiu was proper, given that the pre-trial notice explicitly warned parties that unnamed witnesses might be barred.
The rule regarding the identification of witnesses in the pre-trial brief was an essential safeguard to prevent surprise and ensure a fair trial.

The petitioner obtained a Temporary Restraining Order from the Court, which enjoined the lower court from proceeding with the trial pending resolution of these issues.

Whether it remains proper to question a deficiency in a pre-trial brief on a technical matter after the pre-trial conference has concluded, the Pre-Trial Order has been issued, and the trial is already underway.
Whether the trial court can inhibit a witness from testifying based solely on the fact that the witness’s name is not listed in the pre-trial brief, especially when the Pre-Trial Order did not explicitly contain such a prohibition.
Whether the trial court is justified in banning an unlisted witness in the absence of a specific law mandating such exclusion.
Whether due process considerations should prevail over procedural technicalities, in light of the objective of pre-trial procedures.

Whether the RTC abused its discretion in barring and disqualifying the petitioner’s unnamed witness, Antonia Tiu, along with the potential exclusion of his other witnesses, based solely on non-compliance with the pre-trial witness naming requirement.