G.R. No. 188881 : April 21 2014
FACTS: Republic, through the Presidential Commission on Good Government, commenced a complaint for “reconveyance, reversion, accounting, restitution and damages” against Bienvenido R. Tantoco, Jr., Dominador R. Santiago, Ferdinand E. Marcos, Imelda, R. Marcos, Bienvenido R. Tantoco, Sr., Gliceria R. Tantoco, and Maria Lourdes Tantoco-Pineda. Instead of filing an Answer, respondents Tantoco and Santiago filed a “Motion To Strike Out Some Portions of the Complaint and For Bill of Particulars,” which were both denied. Thereafter, Tantoco and Santiago filed with the Sandiganbayan a pleading denominated “Interrogatories to Plaintiff.” A month later, they filed both an “Amended Interrogatories to Plaintiff” and a Motion for Production and Inspection of Documents. The Sandiganbayan admitted the Amended Interrogatories and granted the Motion for Production and Inspection of Documents. At the conclusion of the pre-trial, the temporary markings of Exhibits “A” to “LLL,” together with their sub-markings, were adopted. However, the PCGG produced and caused the pre-marking of additional documents, Exhibits “MMM” to “AAAAAAA” to which Tantoco and Santiago objected. Tantoco and Santiago filed a “Motion under Rule 29 of the Rules of Court,” claiming that the additional documents were never produced at the discovery proceedings and praying that petitioner be sanctioned for contempt. It was denied by the Sandiganbayan. Trial proceeded; however, new documents not shown at discovery were still being marked. Tantoco and Santiago again filed a “Motion to Ban Plaintiff From Offering Exhibits Not Earlier Marked During the Discovery Proceedings.” Again, it was denied. Petitioner filed its Formal Offer of Evidence. The Sandiganbayan ruled that with the exception of some documents, “all Exhibits… are denied admission. The due execution and authenticity of these documents remain challenged since the prosecution failed to show otherwise. Exhibits “MMM” to “AAAAAAA” were admitted. Respondents, in turn, filed their Motion for Reconsideration, to which the graft court issued a resolution stating that the plaintiff Republic must be prevented from offering in evidence all the documents that were not produced and exhibited at the time the plaintiff was under a directive to do so, i.e. Exhibits “MMM” to “AAAAAAA.”
ISSUE: Whether or not the documents due to petitioner’s own failure to produce them at the pre-trial should be excluded? Yes.
HELD: YES. Court finds that in excluding Exhibits “MMM” to “AAAAAAA,” the Sandiganbayan properly exercised its discretion over evidence formally offered by the prosecution. Petitioner failed to obey the mandate of G.R. No. 90478, which remains an important case on pre-trial and discovery measures to this day; the rationale of these rules, especially on the production of documents, must be constantly kept in mind by the bar: The message is plain. It is the duty of each contending party to lay before the court the facts in issue-fully and fairly; i.e., to present to the court all the material and relevant facts known to him, suppressing or concealing nothing, nor preventing another party, by clever and adroit manipulation of the technical rules of pleading and evidence, from also presenting all the facts within his knowledge. The truth is that “evidentiary matters” may be inquired into and learned by the parties before the trial. Indeed, it is the purpose and policy of the law that the parties – before the trial if not indeed even before the pre-trial – should discover or inform themselves of all the facts relevant to the action, not only those known to them individually, but also those known to adversaries; in other words, the desideratum is that civil trials should not be carried on in the dark; and the Rules of Court make this ideal possible through the deposition-discovery mechanism set forth in Rules 24 to 29.