Case Summary (G.R. No. 89376)
Allegations and Initial Proceedings
On April 23, 1970, an information for bigamy was filed against Avelino C. Agulto. The accusation stemmed from Agulto's second marriage to Andrea Suico on December 30, 1968, while his first marriage to Maria Pilar Gaspar was still in effect, thus, allegedly making his second marriage unlawful. Following the trial, and prior to judgment promulgation, Agulto filed a motion on November 12, 1975, seeking to reopen the trial based on newly-discovered evidence—specifically, a purported marriage contract evidencing that Suico had previously married Romeo Vergeire on July 19, 1960.
Denial of Motion to Reopen Trial
The trial court denied Agulto's motion on March 23, 1976, citing undue delay and the fact that Agulto could have discovered this evidence sooner since he had knowledge of Suico’s previous marriage as early as October 17, 1972. Subsequent motions for reconsideration were also denied, leading Agulto to seek relief from the Court of Appeals, claiming that the trial judge had abused his discretion in denying the request to consider the new evidence.
Court of Appeals’ Findings
In opposing Agulto's petition, the respondents pointed out significant defects with the alleged newly-discovered evidence. The marriage contract did not bear an official seal or certification from the justice of the peace who officiated the marriage, lacked essential identification of the municipality and province, and suggested the marriage occurred without a valid marriage license. The Court of Appeals, highlighting these shortcomings, ultimately denied the petition for certiorari, asserting that the trial court had acted within its discretion.
Legal Principles and Distinctions
The Supreme Court discussion bifurcated between a Motion for New Trial and a Motion to Reopen Trial. The former can be filed after judgment and within the period for perfecting an appeal, while the latter is only permitted after the parties have formally offered their evidence and closed the trial, but before judgment. Although the Rules of Court do not provide specific provisions for motions to reopen trials, this practice is acknowledged in legal tradition and rests on the principles of justice. The prerogative to reopen a case resides with the trial court's discretion, and appellate review is limited to instances of clear abuse of such discretion.
Resolution
Upon evaluating the merits of Agulto's appeal, the Supreme Court held that his claims do not satisfy the requirements for reopening the trial
...continue readingCase Syllabus (G.R. No. 89376)
Case Information
- Petitioner: Avelino C. Agulto
- Respondents: Hon. Court of Appeals, Hon. Francisco Z. Consolacion (Presiding Judge of Branch II of the Court of First Instance of Davao), The People of the Philippines
- G.R. No.: 52728
- Date of Decision: January 17, 1990
- Decision by: Justice Grino-Aquino
Background of the Case
- An information for bigamy was filed against Avelino C. Agulto on April 23, 1970.
- The allegation was that, on December 30, 1968, Agulto contracted a second marriage with Andrea Suico while still married to Maria Pilar Gaspar, his first wife.
- The petitioner claimed that he was unaware of the circumstances surrounding Suico's marital status, which was crucial to his defense.
Motion to Reopen Trial
- After the trial concluded but before the judgment was rendered, Agulto filed a motion on November 12, 1975, to reopen the trial.
- The basis for this motion was the discovery of a marriage contract between Andrea Suico and Romeo Vergeire dated July 19, 1960, suggesting Suico was previously married before her union with Agulto.
- The court denied the motion on March 23, 1976, citing the delay in filing and the potential for the evidence to have been discovered sooner.
Court of Appeals Decision
- Following the trial court's denial of his motion, Agulto filed a petition