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DOMINGO DE GUZMAN v. SANDIGANBAYAN

This case has been cited 9 times or more.

2013-10-17
REYES, J.
It is also recognized that in some instances, the prudent action towards a just resolution of a case is for the Court to suspend rules of procedure, for "the power of this Court to suspend its own rules or to except a particular case from its operations whenever the purposes of justice require it, cannot be questioned."[64] In De Guzman v. Sandiganbayan,[65] the Court, thus, explained: [T]he rules of procedure should be viewed as mere tools designed to facilitate the attainment of justice. Their strict and rigid application, which would result in technicalities that tend to frustrate rather than promote substantial justice, must always be avoided. Even the Rules of Court envision this liberality. This power to suspend or even disregard the rules can be so pervasive and encompassing so as to alter even that which this Court itself has already declared to be final, as we are now compelled to do in this case. x x x.
2012-08-29
BERSAMIN, J.
The principle of substantial compliance recognizes that exigencies and situations do occasionally demand some flexibility in the rigid application of the rules of procedure and the laws.[26] That rules of procedure may be mandatory in form and application does not forbid a showing of substantial compliance under justifiable circumstances,[27] because substantial compliance does not equate to a disregard of basic rules. For sure, substantial compliance and strict adherence are not always incompatible and do not always clash in discord. The power of the Court to suspend its own rules or to except any particular case from the operation of the rules whenever the purposes of justice require the suspension cannot be challenged.[28] In the interest of substantial justice, even procedural rules of the most mandatory character in terms of compliance are frequently relaxed. Similarly, the procedural rules should definitely be liberally construed if strict adherence to their letter will result in absurdity and in manifest injustice, or where the merits of a party's cause are apparent and outweigh considerations of non-compliance with certain formal requirements.[29] It is more in accord with justice that a party-litigant is given the fullest opportunity to establish the merits of his claim or defense than for him to lose his life, liberty, honor or property on mere technicalities. Truly, the rules of procedure are intended to promote substantial justice, not to defeat it, and should not be applied in a very rigid and technical sense.[30] Petitioner urges the Court to resolve the apparent conflict between the rulings in Heirs of Pedro Cabais v. Court of Appeals[31] (Cabais) and in Heirs of Ignacio Conti v. Court of Appeals[32] (Conti) establishing filiation through a baptismal certificate.[33]
2010-07-30
CARPIO MORALES, J.
For rules of procedure must be viewed as tools to facilitate the attainment of justice, such that any rigid and strict application thereof which results in technicalities tending to frustrate substantial justice must always be avoided.[9]
2009-12-04
BERSAMIN, J.
In De Guzman v. Sandiganbayan,[10] the Court had previously denied with finality the petitioner's motion for reconsideration of its decision affirming his conviction by the Sandiganbayan of a violation of Section 3 (e) of Republic Act No. 3019. The petitioner nonetheless took a novel recourse by filing a so-called omnibus motion for leave to vacate first motion for reconsideration in the light of the present developments and to consider evidence presented herein and to set aside conviction. Citing a transcendental reason, that the accused was then about to lose his liberty simply because his former lawyers had pursued a "carelessly contrived procedural strategy of insisting on what has already become an imprudent remedy" that had forbade him from offering his evidence although all the while available for presentation, the Court used its pervasive and encompassing power to alter even that which it had already declared final, and directed the remand of the case to the Sandiganbayan, to allow the evidence of the accused to be received and appreciated, holding that: xxx To cling to the general rule in this case is only to condone rather than rectify a serious injustice to petitioner whose only fault was to repose his faith and entrust his innocence to his previous lawyers. xxx
2009-07-13
CORONA, J.
Nevertheless, in the interest of justice and to prevent undue delay in the disposition of this case, we tackle the next issue raised by petitioner despite the CA's proper dismissal of her petition.[15] This was a criminal case and the possibility of a person being deprived unjustly of her liberty due to the procedural lapse of counsel was a strong and compelling reason to warrant suspension of the Rules of Court.[16] For the rule-making power of this Court is coupled with the duty to protect and promote constitutional and substantive rights,[17] not to defeat them. Thus, the rules of procedure should be viewed as mere tools designed to facilitate the attainment of justice. Their strict and rigid application, resulting in technicalities that tend to frustrate rather than promote substantial justice, must always be avoided.[18]
2009-01-27
AUSTRIA-MARTINEZ, J.
Petitioners insist that they are not bound by the mistake of their counsel, citing De Guzman v. Sandiganbayan[32] and Samala v. Court of Appeals.[33]
2005-06-09
YNARES-SANTIAGO, J.
In the case at bar, the extreme penalty of more than a double-life sentence was imposed. No less than his liberty is at stake here.[15] Consequently, this case deserves to be deliberated upon, moreso because after the initial assessment by the Sandiganbayan, petitioner's only and last resort is with this Court.
2005-03-04
SANDOVAL-GUTIERREZ, J.
In De Guzman v. Sandiganbayan,[9] we remanded the case for reception of evidence after counsel for the accused filed a demurrer to the evidence notwithstanding that his motion for leave of court was denied, thus precluding the accused to present his evidence.
2000-02-29
KAPUNAN, J.
Petitioner, however, implores the Court to be liberal in the application of technical rules of procedure (which in this instance refer to the requisites of a proper notice of hearing) and cites a plethora of cases[16] in support thereof. He reasons out that the defective notice of hearing in his motion for reconsideration was due to the day-long brown-outs that plagued the metropolis and which caused his counsel to have the above pleading prepared outside the law office. In view of this peculiar circumstance, counsel's failure to specify the date and time for the hearing of petitioner's motion for reconsideration should rightly be deemed excusable negligence.