CRIM PRO DIGEST: People v. Sandiganbayan (GR No. 149495)

Criminal Procedure, Digest focusing on Rule 119: Consolidation of Trials of Related Offenses


GR No. 149495                     August 21, 2003


PEOPLE OF THE PHILIPPINES, Petitioner.


v.


THE HONORABLE SANDIGANBAYAN (FIRST DIVISION) and  JOSE JAIME POLICARPIO, Respondents.


PANGANIBAN, J.:


DOCTRINE:

The consolidation of cases is within the discretion of judges, and unless such discretion is gravely abused, appellate courts will not disturb their findings and conclusions.


FACTS:

  • Three cases were filed before the Sandiganbayan (SBN): Plunder against Joseph Ejerity Estrada, illegal use of alias against Estrada, and indirect bribery against the private respondent.

  • Motions to consolidate two of these cases with the plunder case were filed by the petitioner.

  • The Fifth Division granted the consolidated of oe case, while the First Division denied the consolidation of another.

  • The Petition sought to nullify the denial of the consolidation motion for trials of Criminal Case No, 26566 (indirect bribery) with Criminal Case No. 26558 (plunder).


ISSUE:

Whether or not the Sandiganbayan a gravely abused its discretion in denying the consolidation motion for the trials of Criminal Case No. 26566 (indirect bribery) and Criminal Case No. 26558 (plunder).


HELD:

The petition is dismissed due to the ff.:

  1. Consolidation of Trial

    • Consolidation is a matter of judicial discretion, as per Section 22 of Rule 119 and Rule XII of the SBN Revised Internal Rules.

    • Requisites for consolidation include cases arising from the same incident, involving common questions of fact abd law, and depending substantially on the same evidence

    • Consolidation aims to avoid multiplicity of suits, guard against oppression, prevent delay, clear congested dockets, simply the work of the trial court, and saves costs.

    • The ddenia of consolidation is justified in this case to avoid exposing the private respondent to unrelated testimonies, prevent delays, and avoid a lengthy leg battle.

  2. Forum-Shopping

    • Petitioner is found guilty of Forum-Shopping by filing a similar consolidation motion before the SBN while the present petition was pending.

    • Forum-shopping occurs when a party repetitively avails itself of several judicial remedies in different venues, substantially founded on te same transactions, abd raising the same issues involving the same parties.

    • Violation of the forum-shopping prohibition is a ground for summary dismissal.

  3. Supervening Events

    • Petitioner filed a Joint Motion for Provisional Dismissal of Criminal Case No. 26566, which was denied.

    • A second Urgent Motion for consolidation for testimonial evidence purposes.

    • Respondent filed a Manifestation with Motion, alleging willful and deliberate forum-shopping.

    • The Special Division had already heard testimonies relevant to the indirect bribery case.



SOURCE:

G.R. No. 149495. (n.d.). https://lawphil.net/judjuris/juri2003/aug2003/gr_149495_2003.html


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