This case has been cited 3 times or more.
2012-02-07 |
BRION, J. |
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In People v. Leviste,[30] we stressed that the State, like any other litigant, is entitled to its day in court; in criminal proceedings, the public prosecutor acts for and represents the State, and carries the burden of diligently pursuing the criminal prosecution in a manner consistent with public interest.[31] The State's right to be heard in court rests to a large extent on whether the public prosecutor properly undertook his duties in pursuing the criminal action for the punishment of the guilty.[32] | |||||
2010-08-25 |
VILLARAMA, JR., J. |
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Public respondent seriously erred in denying the motion to reopen for presentation of additional evidence on the basis of the supposed "final and executory" ruling which denied admission of Exhibits "B" to "E" in the Formal Offer of Evidence filed by the petitioner. Admission of additional evidence is addressed to the sound discretion of the trial court. Indeed, in the furtherance of justice, the court may grant the parties the opportunity to adduce additional evidence bearing upon the main issue in question.[26] The remedy of reopening a case for presenting further proofs was meant to prevent a miscarriage of justice.[27] | |||||
2006-10-27 |
CALLEJO, SR., J. |
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The same observation was made in Valencia v. Sandiganbayan.[67] Here, the Court noted the haphazard manner by which the prosecutor handled the litigation for the State when he rested the case without adducing evidence for the prosecution and simply relying on the Joint Stipulation of Facts, which the accused did not even sign before its submission to the Sandiganbayan. In allowing the prosecution to present additional evidence and in dismissing the claim of the accused that his constitutional right to a speedy trial had been violated, we ruled: As significant as the right of an accused to a speedy trial is the right of the State to prosecute people who violate its penal laws. The right to a speedy trial is deemed violated only when the proceeding is attended by vexatious, capricious and oppressive delays x x x [T]o erroneously put premium on the right to speedy trial in the instant case and deny the prosecution's prayer to adduce additional evidence would logically result in the dismissal of the case for the State. There is no difference between an order outrightly dismissing the case and an order allowing the eventual dismissal thereof. Both would set a dangerous precedent which enables the accused, who may be guilty, to go free without having been validly tried, thereby infringing the interest of the society.[68] Certainly, the right to speedy trial cannot be invoked where to sustain the same would result in a clear denial of due process to the prosecution. It should not operate in depriving the State of its inherent prerogative to prosecute criminal cases or generally in seeing to it that all those who approach the bar of justice is afforded fair opportunity to present their side.[69] For it is not only the State; more so, the offended party who is entitled to due process in criminal cases.[70] In essence, the right to a speedy trial does not preclude the people's equally important right to public justice.[71] Thus, as succinctly decreed in State v. McTague:[72] The constitutional and statutory provisions for a speedy trial are for the protection of the defendant, but that does not mean that the state is the only one that may initiate action. There is really no reason for the courts to free an accused simply because a dilatory prosecutor has "gone to sleep at the switch" while the defendant and his counsel rest in silence. These solicitous provisions are not to be used as offensive weapons, but are for the benefit of defendants who claim their protection. They are a shield, and they "must not be left hanging on the wall of the armory." It is for the protection of personal rights, not to embarrass the administration of the criminal law nor to defeat public justice. Be that as it may, the conduct of the City Prosecutor and the MTC must not pass without admonition. This Court must emphasize that the State, through the court and the public prosecutor, has the absolute duty to insure that the criminal justice system is consistent with due process and the constitutional rights of the accused. Society has a particular interest in bringing swift prosecutions, and the society's representatives are the ones who should protect that interest. The trial court and the prosecution are not without responsibility for the expeditious trial of criminal cases. The burden for trial promptness is not solely upon the defense. The right to a speedy trial is constitutionally guaranteed and, as such, is not to be honored only for the vigilant and the knowledgeable.[73] |