Case Summary (G.R. No. 188881)

Petition for Certiorari

• The Republic of the Philippines filed a Petition for Certiorari under Rule 65 to nullify a Sandiganbayan Resolution dated June 3, 2009.
• The Resolution denied the admission of Exhibits "MMM" to "AAAAAAA" in the Formal Offer of Evidence submitted by the Republic.

Background of the Case

• The complaint initiated by the Republic through the Presidential Commission on Good Government (PCGG) sought "reconveyance, reversion, accounting, restitution, and damages" against several respondents, including Bienvenido R. Tantoco, Jr. and Dominador R. Santiago.
• Respondents filed motions to strike portions of the complaint and for a bill of particulars, which were denied.
• The Sandiganbayan later admitted amended interrogatories and granted a motion for production and inspection of documents.

Pre-Trial Proceedings

• Pre-trial commenced, and the PCGG produced documents marked as Exhibits "A" to "LLL" from January to July 1993.
• The pre-trial was declared closed on September 10, 1996, but additional documents (Exhibits "MMM" to "AAAAAAA") were produced over the objections of the respondents.
• Respondents filed motions claiming the additional documents were not produced during discovery and sought sanctions against the petitioner.

Trial and Admission of Evidence

• The trial proceeded, but new documents continued to be marked, leading to further motions from respondents to exclude these documents.
• The Sandiganbayan ruled on January 15, 2008, that most exhibits were denied admission due to challenges regarding their execution and authenticity.
• Following a motion for reconsideration, the Sandiganbayan admitted some exhibits but later excluded Exhibits "MMM" to "AAAAAAA" in its June 3, 2009 Resolution.

Sandiganbayan's Rationale for Exclusion

• The Sandiganbayan found that the Republic failed to produce the documents during pre-trial as directed, leading to the exclusion of the exhibits.
• The court emphasized that the exhibits had not passed the test of admissibility and that the prosecution did not demonstrate their due execution and authenticity.

Supreme Court's Review of Sandiganbayan's Discretion

• The Supreme Court reviewed whether the Sandiganbayan committed grave abuse of discretion in excluding the documents.
• The Court found that the Sandiganbayan properly exercised its discretion and that the petitioner did not show that the court acted arbitrarily or capriciously.

Petitioner’s Arguments and Court's Response

• The petitioner argued that the Sandiganbayan's earlier resolutions indicated a more lenient approach to the admissibility of evidence.
• The Supreme Court clarified that the admissibility of evidence is determined at the time of formal offer, and prior rulings do not guarantee future admissibility.

Best Evidence Rule and Authentication

• The Supreme Court discussed the Best Evidence Rule, which requires the original document to be produced when its contents are in issue.
• The Court noted that the petitioner failed to authenticate private documents and did not meet the requirements for public documents.

Conclusion on the Petition

• The Supreme Court affirmed the Sandiganbayan's resolution, co...continue reading