Case Summary (G.R. No. 2549)
Case Background
The record of the case was transmitted from the Court of First Instance to the relevant appellate court on March 30, 1905. The court ordered the records to be sent to the Attorney-General’s office on April 5, 1905, for translation into Spanish. The records included a certificate from the stenographer indicating that all evidence recorded pertained solely to the testimony of witnesses for the defendant, alongside a single rebuttal witness presented by the government.
Discrepancies in the Evidence
Upon receipt of the records, it was noted that the translation introduced a statement by the fiscal in the original trial which referenced signed statements from witnesses examined during a preliminary investigation. However, such a statement was absent in the original documentation sent to the Attorney-General’s office, leading the court to conclude that this statement should be disregarded.
Procedural Errors and Non-Compliance
The original record indicated that six witnesses were presented by the government during the trial; however, the evidence related to these witnesses was not preserved as mandated by Section 32 of General Orders No. 58. A manuscript purporting to contain an abstract of their testimonies was not signed or certified, failing to meet the necessary legal standards for evidence documentation.
Legal Precedents and Conclusion
Citing decisions from prior cases such as U. S. vs. Pablo Tan, U. S. vs. Hollis, and U. S. vs. Quilatan, the court determined that the procedural shortcomings warranted the reversal of the judgment. Consequently, a new trial was ordered, allowing either party to introduce additional evidence but not requiring the reintroduction of evidence that had already
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Case Information
- Court: Supreme Court of the Philippines
- Date of Decision: August 15, 1906
- G.R. No.: 2549
- Plaintiff/Appellee: The United States
- Defendant/Appellant: Emeterio Dacanay
Background of the Case
- The record in this case was received by the Supreme Court from the Court of First Instance on March 30, 1905.
- An order was made on April 5, 1905, to transfer the record to the Attorney-General's office for translation into Spanish.
- The initial record contained a certificate from the stenographer indicating that it comprised all the evidence taken in the case, limited to the testimonies of the defendant’s witnesses and one government witness for rebuttal.
Procedural History
- Upon returning from the Attorney-General's office, the translated record included a statement that the fiscal presented signed statements made by witnesses examined before a justice of the peace during the preliminary investigation.
- This statement was not part of the original record sent to the Attorney-General's office and thus was disregarded by the Supreme Co