Title
People vs Donato
Case
G.R. No. L-3905
Decision Date
Oct 17, 1907
Defendants convicted based on unlawful agreements between prosecution and defense; Supreme Court nullified judgment, citing procedural violations, and ordered a new trial.

Case Summary (A.C. No. 6281)

Events Leading to the Appeal

The Court found that several agreements were made between the Government’s representative and the defense attorneys. One agreement concerned the prosecution’s evidence and provided that four more witnesses would affirm the declaration for the prosecution. Another agreement addressed the defense position and recited that three witnesses would testify that the accused Hilario Tabucly and Gregorio Sapla were in the pueblo of Cabugao on the days in question, and that three other witnesses would likewise testify that the accused Juan Baldivino was with them in a barrio of the pueblo of Badoc on the same days. The agreement further stated that all accused, while denying the charges, would declare that Juan Baldivino did not attend the function referred to by Prudencia Ragosante, and that the accused did not know one another because they came from different pueblos. The declarations of the witnesses and of the accused were received verbally, and the defense attorneys treated the defense as complete and asked for acquittal.

Trial Court Ruling and the Conviction

Despite the defense theory grounded on an alibi, the court below held that the commission of the crime by the accused was corroborated. It reasoned that corroboration existed in the “form and manner” by which the alibi witnesses had testified. Based on that assessment, the court below sentenced the accused to eight years and one day of presidio mayor, and it imposed the accessories stated in its judgment. The accused appealed from that conviction.

The Appellate Court’s Evaluation of the Record

On review, the Court declared that it found itself unable to review the evidence properly. The Court attributed this inability to a “reprehensible abuse” committed through resort to unlawful agreements. The Court held that these agreements frustrated the purposes of the law and had been openly violated, expressly citing Sec. 32, General Orders, No. 58.

Disposition and Order for a New Trial

Because of the unlawful and abusive manner in which the proceedings were conducted, the Cou

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