DOMINGO DE GUZMAN v SANDIGANBAYAN (2nd Division) & PEOPLE OF THE PHIL.

256 SCRA 171 | April 11, 1996

Francisco, J.

Doctrine: An accused cannot be held liable for a mistake committed by counsel especially if
it will impede the administration of justice.

FACTS
Petitioner in this case was convicted by the Sandiganbayan of violation of Sec 3(e) of the
Anti-Graft and Corrupt Practices Act for alleged failure to account for P200,000 received for
certain official training program of the Department of Agriculture. The said decision was
affirmed by an En Bacn Resolution and denied with finality the motion for reconsideration filed
by the petitioner. Left with no recourse and to prevent his looming imprisonment, petitioner now
comes before the Court by filing the Omnibus Motion to Vacate First Motion For
Reconsideration In the Light of the Present Developments And To Consider Evidence Presented
Herein And To Set Aside Conviction. This new motion was filed by a new counsel and alleges
that the Court relieve the petitioner from a serious and costly mistake of his former lawyers in
demurring to the prosecution evidence after court leave was denied which effectively deprived
him of presenting documentary evidence which would belie the accusations against him.
Petitioner also attached an annex of the said evidence containing receipts and liquidations
vouchers to bolster her claim.
When asked to comment about the said manner, the Office of the Solicitor General argue
that the petitioner is bound by the mistake of his former lawyers and that the evidence which he
attempts to present would not cast a reasonable doubt for his guilt of the crime charged. In his
answer, petitioner contends that to adhere to the general rule that the client is bound by his
counsels’ mistake will deprive him of his liberty through a technicality and that the evidence he
seeks to present will disprove his guilt before the Court.

ISSUES AND HOLDING

1. W/N the petitioner is bound by the mistakes of his former counsels? – NO.
It is a well-settled rule that the Court has the power to suspend its own rules or even
mandatory procedural rules whenever the purposes of justice require it, especially when
the matters involved are of transcendental importance such as life, liberty or State
security. Rules of procedure should be viewed as mere tools designed to facilitate
attainment of justice, not impede it. In the present case, what is at stake is the liberty of
the petitioner and this is due to an erroneous and careless decision on the part of his
former counsels to pursue a wrong remedy which effectively denied petitioner of his
chance to present the evidence which would negate his guilt in the crime charged against
him. Under the circumstances, higher interests of justice and equity demand that
petitioner be not penalized for the costly decisions of his previous lawyers and the
evidence must be appreciated to support his cost.

WHEREFORE, petitioners Omnibus Motion is GRANTED and the Courts April 12, 1994
Decision and June 16, 1994 Resolution are hereby RECONSIDERED. Accordingly, let this
case be REMANDED to the Sandiganbayan for reception and appreciation of petitioners
evidence. No costs.

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