Case Summary (G.R. No. 84857)
Procedural History and Trial Proceedings
The District Court initially held a pre-trial conference on February 15, 2005. Both accused, Zaldivar and co-accused Jeanette Artajo, pleaded not guilty. During trial, the prosecution presented live witnesses who identified their affidavits as their direct testimonies. Zaldivar’s counsel did not cross-examine these witnesses, and Artajo’s counsel waived cross-examination by absence. After a motion for inhibition against Judge Virgilio Patag was granted, the case was re-raffled to Judge Edgardo Catilo, Branch 23.
RTC Orders Challenged by Zaldivar
On November 18, 2005, Judge Catilo issued an order denying the admission of the prosecution’s exhibits, nullifying previous proceedings due to alleged procedural due process violations, and ordering a new pre-trial conference set for January 19, 2006. Zaldivar moved to declare the prosecution’s case terminated, which was denied by the RTC on March 10, 2006, and her motion for reconsideration was similarly denied on June 20, 2006.
Petition for Certiorari before the Court of Appeals
Zaldivar filed a petition under Rule 65 before the CA presenting two main issues: (1) whether the prosecution’s presentation of only witness affidavits constituted competent evidence to prove guilt and (2) whether Judge Catilo committed grave abuse of discretion in nullifying earlier proceedings and ordering a new pre-trial.
Court of Appeals Decision
The CA reversed the RTC orders, ruling that the manner of evidence presentation left to the prosecution’s discretion could not be grounds to terminate the case. It found Judge Catilo’s nullification of previous proceedings and the order for a new pre-trial as grave abuse of discretion, tantamount to prejudicial reopening of trial. The CA noted that procedural lapses should have been remedied by recalling witnesses under Section 9, Rule 132 of the Rules of Court, instead of annulling the entire proceedings. The CA also held that the original pre-trial conference conducted complied with the mandated requirements under Section 1, Rule 118 of the Rules of Criminal Procedure.
Petitioner’s Arguments in the Supreme Court
Zaldivar contended that the denial to admit prosecution exhibits effectively terminated the prosecution’s case due to insufficiency of evidence and thus the case should have been dismissed rather than reopened. She further claimed that a second pre-trial constituted double jeopardy—being tried twice for the same charge.
Supreme Court Ruling
The Supreme Court affirmed the CA decision, emphasizing that questions regarding the sufficiency of evidence are factual issues to be resolved by the trial court following full trial. Termination of the prosecution’s case is proper only upon a demurrer to evidence or on court initiative after appropriate hearing, neither of which occurred. The Court stressed that the trial court erred in nullifying the pre-trial proceedings and ordering a new pre-trial without sufficient basis, thus committing grave abuse of discretion. The appropriate remedy for procedural defects in witness presentation was to recall witnesses as allowed by Section 9, Rule 132 of the Rules of Court.
Regarding the alleged insufficiency of the Pre-Trial Order, the Court found that the February 15, 2005 pre-trial complied substantially with the requirements of Section 1, Rule 118, including marking of evidence, raising of objections, and identifying issues. The Court reiterated that pre-trial aims to simplify and expedite the trial, and setting aside duly conducted proceedings without compelling reasons undermines this objective.
Legal Principles Applied
- Under the 1987 Philippine Constitution and the Revised Rules of Criminal Procedure, sufficiency of evidence is primarily a matter for the trial court to
Case Syllabus (G.R. No. 84857)
Background and Procedural History
- Fe P. Zaldivar, together with Jeanette Artajo, was charged with Estafa based on a complaint filed by Mamerto Dumasis before the Regional Trial Court (RTC) of Iloilo City, initially raffled to Branch 33.
- A pre-trial conference was held on February 15, 2005, resulting in the issuance of a Pre-Trial Order.
- Both accused pleaded not guilty upon arraignment.
- The prosecution presented witnesses Alma Dumasis and Delia Surmieda who identified their affidavits as their direct testimonies.
- Zaldivar’s counsel chose not to cross-examine, and Artajo's counsel was deemed to have waived the right to cross-examine due to absence.
- Mamerto Dumasis filed a Motion for Inhibition against the original trial judge, Virgilio Patag, which was granted, leading to re-raffling of the case to Branch 23 under Judge Edgardo Catilo.
- On November 18, 2005, RTC Branch 23 issued an order nullifying previous proceedings and denying prosecution exhibits due to procedural due process concerns; it reset the case for a new pre-trial.
- Zaldivar filed a motion to declare the prosecution’s case terminated, which was denied along with her motion for reconsideration.
- She then filed a petition for certiorari with the Court of Appeals (CA), questioning (1) the sufficiency of the prosecution’s evidence presented through affidavits only, and (2) the alleged grave abuse of discretion by Judge Catilo in nullifying earlier proceedings and ordering a new pre-trial.
Issues Presented
- Whether the presentation of prosecution witnesses solely through their affidavits without live testimony failed to sufficiently prove the alleged crime, warranting dismissal of the criminal case.
- Whether Judge Catilo committed grave abuse of discretion when he nullified the proceedings previously conducted in Branch 33 and ordered a new pre-trial conference.
Court of Appeals Ruling
- The CA reviewed the findings of the RTC Branch 23 and set aside the orders nullifying prior proceedings and denying the admission of exhibits.
- It held that the prosecution’s approach in presenting evidence by affidavits was within its discretion, falling under the trial court’s purview to assess during trial.
- The CA ruled that Judge Catilo abused discretion by ordering a new pre-trial as this equated to a new trial, infringing upon the rights of the accused.
- It found that the judge lacked authority to nullify completed proceedings and that procedural corrections should have been done by recalling witnesses pursuant to Section 9, Rule 132 of the Rules of Court.
- The CA also