G.R. No. 207153 - Development Bank of the Philippines vs. Monsanto Co.

In July 2004, the city prosecutor filed four Informations for grave oral defamation at the Metropolitan Trial Court of Quezon City, Branch 43, based on a complaint by Josephine ABL Vigden against Deogracia M. Valderrama.
During the trial on April 12, 2012, despite Vigden’s presence, the private prosecutor did not appear. Subsequently, on the defense’s motion, the court ruled that the prosecution had waived its right to present further evidence and directed that any documentary evidence be formally offered within five (5) days.

On May 8, 2012, Vigden filed a Very Urgent Motion to Reconsider the April 12, 2012 Order. In her motion, she explained that the private prosecutor’s absence was due to the need to manage high blood pressure.
Deogracia Valderrama opposed the motion by raising several procedural defects:

The motion lacked the conformity of the public prosecutor as required under Rule 110, Section 5 of the Rules of Court.
It did not contain a proper notice of hearing addressed to all parties with the specific time and date, thereby not complying with Rule 15, Sections 4 and 5.
The motion was filed beyond the prescribed fifteen (15)-day reglementary period.
There was an absence of a supporting statement of material dates and affidavits, and no denial that the private respondent had failed to cooperate with the public prosecutor.

On July 16, 2012, the Metropolitan Trial Court granted the Motion to Reconsider and set a final date (November 22, 2012) for the prosecution to offer its documentary evidence, effectively lifting and setting aside the previous ruling declaring the prosecution’s waiver.
Later, Valderrama sought reconsideration of the July 16, 2012 Order; however, the Metropolitan Trial Court denied the motion on August 31, 2012.
Valderrama then filed a petition for certiorari before the Regional Trial Court which, in its May 3, 2013 Decision, found no grave abuse of discretion.
The Court of Appeals affirmed the Regional Trial Court’s ruling in its March 9, 2015 Decision and later denied the motion for reconsideration in its July 23, 2015 Resolution.

Valderrama filed a Petition for Review on Certiorari challenging the rulings of the Court of Appeals and seeking the annulment of the Metropolitan Trial Court’s Orders dated July 16, 2012 and August 31, 2012.
She contended that the trial court’s approval of the defective Motion to Reconsider amounted to a grave abuse of discretion and stressed that the motion’s patently defective nature was not a mere error of judgment but involved a disregard of mandatory procedural rules.
Vigden, through her comment and with the support of the Office of the Solicitor General, opposed the petition by asserting that both parties were given their fair opportunity and that any error committed was one of judgment, not jurisdiction.

Whether the Metropolitan Trial Court committed grave abuse of discretion by granting the Motion to Reconsider despite it being burdened with multiple procedural defects.

Specifically, the issue centers on the failure to obtain the required conformity of the public prosecutor as mandated by Rule 110, Section 5 of the Rules on Criminal Procedure.
Whether the Motion to Reconsider’s lack of a proper notice of hearing, as required under Rule 15, Sections 4 and 5, rendered it fatally defective.
Whether the filing of the Motion to Reconsider beyond the fifteen (15)-day reglementary period should preclude the trial court from allowing the prosecution to continue its presentation of evidence.
Whether the alleged defects in the motion substantively deprived de facto due process and affected the accused’s right to a speedy trial.