Bayas vs. Sandiganbayan

Pre-trial stipulations of facts and documents duly signed by the accused and their counsel are valid and binding and may not be unilaterally withdrawn before the commencement of trial, the court's approval not being required to make them binding; they may be set aside only for good cause, such as collusion, duress, fraud, misrepresentation as to facts, or undue influence. The power to relieve a party from a validly made stipulation lies in the sound discretion of the court, which will not be disturbed on appeal unless exercised with grave abuse.

Petitioners Ernesto T. Matuday and Sixto M. Bayas were, respectively, the municipal mayor and municipal treasurer and designated municipal accountant of the Municipality of Kabayan, Province of Benguet, during the period relevant to the case. They were charged before the Sandiganbayan in their official capacities with violation of Section 3(e) of RA No. 3019, as amended, and two counts of malversation through falsification penalized under Article 217, in relation to Article 171, of the Revised Penal Code. The proceedings implicated the mandatory pre-trial mechanism under Rule 118 of the Rules of Court, which directs the court, after arraignment, to order a pre-trial conference to consider, among other matters, the stipulation of facts.

On May 6, 1999, three Informations were filed before the Sandiganbayan charging Ernesto T. Matuday and Sixto M. Bayas with violation of Section 3(e) of RA No. 3019, as amended, and two counts of malversation through falsification penalized under Article 217, in relation to Article 171, of the Revised Penal Code. They were charged in their capacities as municipal mayor and municipal treasurer, respectively, of the Municipality of Kabayan, Province of Benguet.

At their arraignment on September 21, 1999, both petitioners pleaded "not guilty." The pre-trial conference scheduled for October 15, 1999 was cancelled and reset to November 5, 1999 because their counsel, Atty. Jose M. Molintas, was not prepared. On November 5, 1999, the pre-trial was again cancelled because of the absence of Atty. Molintas, who was allegedly suffering from the flu. Notwithstanding the cancellation, the Sandiganbayan urged the accused to discuss with their counsel the stipulation of facts drafted by Ombudsman Prosecutor II Evelyn T. Lucero, so that at the resumption of the pre-trial on December 10, 1999, they could expeditiously pass upon all other matters that still remained to be resolved.

On December 10, 1999, the parties submitted a "Joint Stipulation of Facts and Documents," duly signed by the two accused, Atty. Molintas, and Prosecutor Lucero. The stipulation admitted that Matuday was then the municipal mayor and Bayas was and still is the municipal treasurer and designated municipal accountant of Kabayan, Benguet during the period relevant to the case; that both accused admitted the disbursement of the amount of P510,000.00 and P55,000.00; and that the prosecution and defense jointly admitted a list of documentary exhibits, with reservation to mark additional exhibits during trial. The defense was to present at least four witnesses, while the prosecution opted not to present any witness considering that the defense admitted all the documentary evidence of the prosecution.

On January 14, 2000, the pre-trial conference was again scuttled due to the absence of Atty. Molintas, and the hearing was rescheduled for February 14, 2000. On February 7, 2000, he moved to withdraw as counsel for the accused. His motion was granted by the anti-graft court in an Order dated February 14, 2000, which likewise rescheduled the pre-trial for March 31, 2000 to give the accused ample time to employ a new counsel.

On April 26, 2000, the accused, represented by their new counsel, Atty. Cecilia M. Cinco, moved to withdraw the Joint Stipulation of Facts and Documents. Specifically, they sought to withdraw, first, Stipulation 1(b), which states that "Both the accused admit the disbursement of the amount of P510,000.00 and P55,000.00"; and second, Exhibits "1" to "8-a." They invoked their constitutional right to be presumed innocent until proven guilty.

The Sandiganbayan denied the motion. It reasoned that there was an express statement from Atty. Rogelio A. Cortes that neither fraud nor any other mistake of a serious character vitiated the consent of the parties when they affixed their conformity to the stipulations, and that while it saw the possibility that the accused might as well not present any evidence on the entire accusation, that possibility was by itself not a ground for withdrawing any stipulation freely and knowingly made and given. Reconsideration was denied in the second assailed Order, where the anti-graft court reiterated that the fact that the stipulation of facts leaves less or no room for the accused to defend himself is not a ground for setting aside a pre-trial order, and that an accused can plead guilty if he so desires or make admissions as he deems appropriate and truthful. It added that the pre-trial order shall remain and that the admissions therein contained can be used in the case and for whatever purpose the Rules on Evidence will allow.

• Unilateral Withdrawal of Pre-trial Stipulations: Petitioners contended that pre-trial stipulations may be unilaterally withdrawn by the accused because they are not binding until after the trial court has issued a pre-trial order approving them.
• Necessity of a Pre-trial Order: Petitioners argued that the law on pre-trial requires the issuance of a pre-trial order to make pre-trial stipulations binding.
• Incompetence of Former Counsel: Petitioners maintained that their former counsel, in agreeing to the Joint Stipulation, failed to consider their legal interests, and that this justified relief from the stipulation.
• Presumption of Innocence and Constitutional Rights: Petitioners argued that the two questioned items impaired their constitutional right to be presumed innocent, violated their right against self-incrimination, and denied them due process, in the sense that the trial would be a "useless formality, an idle ceremony."

• Withdrawal from the Joint Stipulation: Whether petitioners may be allowed to withdraw unilaterally from the Joint Stipulation of Facts and Documents.
• Grave Abuse of Discretion: Whether the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction in denying petitioners' Motion to Withdraw the Joint Stipulation of Facts and Documents.
• Constitutional Rights: Whether the denial of the withdrawal of the Joint Stipulation would result in manifest injustice and impairment of petitioners' constitutional rights, including the presumption of innocence, the right against self-incrimination, and due process.
• Necessity of a Pre-trial Order: Whether there is a law or rule barring petitioners from withdrawing their Joint Stipulation, or conversely requiring a pre-trial order to make the stipulations binding.

• Withdrawal from the Joint Stipulation: No. Stipulations validly entered into will not be set aside unless for good cause, and the party who validly made them may be relieved only upon a showing of collusion, duress, fraud, misrepresentation as to facts, and undue influence, or of sufficient cause on such terms as will serve justice.
• Necessity of a Pre-trial Order: No. Under Section 2 of Rule 118, a pre-trial agreement need only be in writing and signed by both the accused and their counsel to bind them; the court's approval is not needed and serves merely to emphasize the court's supervision over the case.
• Constitutional Rights: No. The waiver effected by the Joint Stipulation was voluntary, made with the assistance of counsel, and sanctioned by the Rules on Criminal Procedure, so no impairment of the presumption of innocence, due process, or the right against self-incrimination resulted.
• Grave Abuse of Discretion: None. Petitioners failed to prove that the Sandiganbayan exercised its discretion in an arbitrary, capricious, whimsical, or despotic manner, and no bad faith or malice could be imputed to it for the delay, which was due to the continued absence of petitioners' counsel.

• Withdrawal from the Joint Stipulation: Stipulations play an indispensable role in the speedy disposition of cases, and the new Rules on Criminal Procedure mandate parties to agree on matters of facts, issues, and evidence. Once validly entered into, stipulations will not be set aside unless for good cause, and should be enforced especially when they are not false, unreasonable, or against good morals and sound public policy. When made before the court, they are conclusive, and the party who validly made them may be relieved only upon a showing of collusion, duress, fraud, misrepresentation as to facts, and undue influence, or upon a showing of sufficient cause on such terms as will serve justice. The power to relieve a party from a stipulation validly made lies in the court's sound discretion, which will not be disturbed on appeal unless exercised with grave abuse. Here, petitioners did not allege that the stipulations were false or misleading or were obtained through force or fraud; on the contrary, they did not dispute the finding that no fraud or serious mistake vitiated their and their counsel's consent, and they even admitted that they had freely given their consent. Their attempt to blame the alleged incompetence of their former counsel failed because, to be a ground for relief against a stipulation, a mistake must be one of fact — not a mere lack of full knowledge of fact because of failure to exercise due diligence in ascertaining it — and because parties are bound by the action or inaction of their counsel, the rule extending even to the mistakes and simple negligence committed by counsel.

• Necessity of a Pre-trial Order: Section 2 of Rule 118 provides that all agreements or admissions made or entered into during the pre-trial conference shall be reduced in writing and signed by the accused and counsel, otherwise they cannot be used against the accused, and that agreements covering the matters referred to in Section 1 shall be approved by the court. From this provision, only two conditions are required for a pre-trial agreement to bind the accused: the agreement or admission must be in writing, and it must be signed by both the accused and their counsel. The court's approval is not needed to make the stipulations binding; it is necessary merely to emphasize the supervision by the court over the case and to enable it to control the flow of the proceedings. Once the stipulations are reduced into writing and signed by the parties and their counsels, they become binding and constitute judicial admissions of the facts stipulated. Even if placed at a disadvantageous position, a party may not be allowed to rescind them unilaterally and must assume the consequences of the disadvantage. By parity of reasoning with the accused's recognized right to plead guilty under appropriate circumstances, they should likewise be allowed to enter into a fair and true pre-trial agreement. The Sandiganbayan could not be faulted for its failure to approve expressly the stipulations, since it could not fully act on the matter because of the continued absence of petitioners' counsel; the pre-trial conference had to be rescheduled six times just to ensure the attendance of the parties and their counsels. It had the opportunity to rule on the matter only when the accused, through new counsel, moved to withdraw their stipulations, and in its first assailed Order it upheld their validity, thereby effectively approving the submitted Joint Stipulation. The assent of the court to agreements of the parties, assisted by their counsel, is assumed until they indicate a dissent.

• Constitutional Rights: Petitioners failed to convince the Court, other than by generalized argumentation, that the presumption of innocence, the right against self-incrimination, and due process would be violated. The old Rules of Court frowned upon stipulations of facts in criminal cases because of a perceived danger that the prosecution would relieve itself of its duty to prove guilt beyond reasonable doubt by merely stipulating with defense counsel the elements of the crime charged; however, the Rules were amended in 1985 precisely to enable parties to stipulate facts, and the amendment was carried over to the 2000 Revised Rules on Criminal Procedure. The acceptability of stipulating facts has long been established in jurisprudence, as in cases involving illegal possession of firearms, where the prosecution and defense stipulated that the accused had been found in possession of a gun without the required permit or license; in People vs. Bocar, where the Court considered as valid the admission by the accused of the existence of certain affidavits and exhibits to dispense with oral testimonies; and in People vs. Hernandez, involving illegal recruitment, where the Court upheld the joint stipulation that the accused had not been licensed or authorized by the Philippine Overseas Employment Agency to recruit workers for overseas jobs. There is nothing irregular or unlawful in stipulating facts in criminal cases, and the policy encouraging it is consistent with the doctrine of waiver, which recognizes that everyone has a right to waive and agree to waive the advantage of a law or rule made solely for the benefit and protection of the individual in his private capacity, if it can be dispensed with and relinquished without infringing on any public right and without detriment to the community at large. The Joint Stipulation was a waiver of the right to present evidence on the facts and documents freely admitted, and no impairment of constitutional rights could have resulted because the waiver was voluntary, made with the assistance of counsel, and sanctioned by the Rules on Criminal Procedure.

• Grave Abuse of Discretion: The power to relieve a party from a stipulation validly made lies at the sound discretion of the court, and unless exercised with grave abuse, this discretion will not be disturbed on appeal. Grave abuse of discretion exists where a power is exercised in an arbitrary, capricious, whimsical, or despotic manner by reason of passion or personal hostility, so patent and so gross as to amount to evasion of positive duty or virtual refusal to perform a duty enjoined by, or in contemplation of law. Petitioners failed to prove that the Sandiganbayan committed grave abuse of discretion in disallowing them to withdraw the stipulations that they had freely and voluntarily entered into, and no bad faith or malice was or can be imputed to the anti-graft court for failing to act immediately upon the Joint Stipulation, the delay being due not to its deliberate evasion of duty but to the continued absence of petitioners' counsel.

• Binding Effect of Pre-trial Stipulations — Stipulations freely and voluntarily made are valid and binding and will not be set aside unless for good cause. They are greatly favored because they simplify, shorten, or settle litigations in a faster and more convenient manner, save costs, time, and resources, and help unclog court dockets. They should be enforced especially when they are not false, unreasonable, or against good morals and sound public policy, and when made before the court they are conclusive. The Court applied this doctrine in holding that the Joint Stipulation signed by petitioners and their counsel bound them and could not be unilaterally withdrawn.
• Grounds for Relief from a Stipulation — A party who validly made a stipulation may be relieved therefrom only upon a showing of (a) collusion, (b) duress, (c) fraud, (d) misrepresentation as to facts, and (e) undue influence, or upon a showing of sufficient cause on such terms as will serve justice in a particular case. The power to relieve a party from a stipulation validly made lies in the court's sound discretion, which, unless exercised with grave abuse, will not be disturbed on appeal. Petitioners alleged none of these grounds, and the Court found no basis to disturb the Sandiganbayan's denial.
• Mistake as Ground for Relief — To be a ground for relief against a stipulation, a mistake must be one of fact — not a mere lack of full knowledge of fact because of failure to exercise due diligence in ascertaining it. Petitioners' claim that their former counsel failed to consider their legal interests did not qualify as a mistake of fact warranting relief.
• Parties Bound by Counsel's Acts — Parties are bound by the action or inaction of their counsel; to all intents and purposes, the acts of a lawyer in the defense or prosecution of a case are the acts of the client, and the rule extends even to the mistakes and simple negligence committed by counsel. The Court invoked this doctrine to reject petitioners' attempt to escape the stipulation by blaming their former counsel.
• Requisites for a Binding Pre-trial Agreement — Under Section 2 of Rule 118, for a pre-trial agreement to be binding on the accused, (a) the agreement or admission must be in writing, and (b) it must be signed by both the accused and their counsel. The court's approval is not needed to make the stipulations binding; it is necessary merely to emphasize the court's supervision over the case and to enable it to control the flow of the proceedings. The Court held that the Joint Stipulation satisfied both requisites and therefore bound petitioners even absent express approval.
• Judicial Admissions — Once stipulations are reduced into writing and signed by the parties and their counsels, they become binding on the parties who made them and become judicial admissions of the fact or facts stipulated. A party may not be allowed to rescind them unilaterally even if placed at a disadvantageous position, and must assume the consequences of the disadvantage.
• Doctrine of Waiver — Everyone has a right to waive and agree to waive the advantage of a law or rule made solely for the benefit and protection of the individual in his private capacity, if it can be dispensed with and relinquished without infringing on any public right and without detriment to the community at large. The policy encouraging stipulations of facts in criminal cases is consistent with this doctrine, and the Joint Stipulation was a valid waiver of the right to present evidence on the facts and documents admitted.
• Grave Abuse of Discretion — Grave abuse of discretion exists where a power is exercised in an arbitrary, capricious, whimsical, or despotic manner by reason of passion or personal hostility, so patent and so gross as to amount to evasion of positive duty or virtual refusal to perform a duty enjoined by, or in contemplation of law. The Court found no such abuse in the Sandiganbayan's denial of the motion to withdraw.

• "Once validly entered into, stipulations will not be set aside unless for good cause. They should be enforced especially when they are not false, unreasonable or against good morals and sound public policy. When made before the court, they are conclusive." — This passage states the ratio decidendi on the binding force of pre-trial stipulations, the core rule on which the denial of the Petition rested.
• "Based on the foregoing provision, for a pretrial agreement to be binding on the accused, it must satisfy the following conditions: (1) the agreement or admission must be in writing, and (2) it must be signed by both the accused and their counsel. The court's approval, mentioned in the last sentence of the above-quoted Section, is not needed to make the stipulations binding on the parties." — This is the Court's canonical construction of Section 2 of Rule 118, enumerating the requisites for a binding pre-trial agreement and clarifying that judicial approval is not among them.
• "'[G]rave abuse of discretion' where 'a power is exercised in an arbitrary, capricious, whimsical or despotic manner by reason of passion or personal hostility, so patent and so gross as to amount to evasion of positive duty or virtual refusal to perform a duty enjoined by, or in contemplation of law.'" — This passage supplies the definition of grave abuse of discretion applied in disposing of the Rule 65 Petition.
• "To be a ground for relief against a stipulation, a mistake must be one of fact -- not, as in this case, a mere lack of full knowledge of fact because of failure to exercise due diligence in ascertaining it." — This passage defines the character of mistake that may justify relief from a stipulation and disposes of petitioners' reliance on their former counsel's alleged incompetence.

• People vs. Bocar, 27 SCRA 512, March 28, 1969 — Cited as authority that the Court considered valid the admission by the accused of the existence of certain affidavits and exhibits, which the prosecution had presented to dispense with oral testimonies on the matters contained therein; supports the acceptability of stipulating facts in criminal cases.
• People vs. Hernandez, 260 SCRA 25, July 30, 1996 — Cited both for the rule that the old Rules frowned upon stipulations of facts in criminal cases and for the ruling upholding a joint stipulation that the accused had not been licensed or authorized by the Philippine Overseas Employment Agency to recruit workers for overseas jobs; supports the validity of stipulating facts.
• People vs. Mapa, 20 SCRA 1164, August 30, 1967 — Cited as an example of a case involving illegal possession of firearms where the prosecution and defense stipulated that the accused had been found in possession of a gun without the required permit or license.
• Villa Rhecar Bus vs. De La Cruz, 157 SCRA 13, January 7, 1988 — Cited for the doctrine that parties are bound by the action or inaction of their counsel, including counsel's mistakes and simple negligence.
• Legarda vs. CA, 280 SCRA 642, October 16, 1997 — Cited alongside Villa Rhecar Bus for the same doctrine binding parties to the acts of their counsel.
• Dequito vs. Llamas, 66 SCRA 504, September 4, 1975 — Cited for the rule that even if placed at a disadvantageous position, a party may not be allowed to rescind a stipulation unilaterally and must assume the consequences of the disadvantage.
• Gacutana-Fraile vs. Domingo, 348 SCRA 414, December 15, 2000 — Cited for the principle that allowing parties to renege on stipulations validly entered into during pre-trial proceedings would result in no end to litigations.
• Baylon vs. Office of the Ombudsman, G.R. No. 142738, December 14, 2001 — Cited as the source of the Court's definition of grave abuse of discretion.
• People vs. Donato, 198 SCRA 130, June 5, 1991 — Cited, through Herrera's Remedial Law, for the doctrine of waiver recognizing the right to waive the advantage of a law or rule made solely for the benefit and protection of the individual in his private capacity.
• Muñoz vs. People, 53 SCRA 190, September 28, 1973 — Cited for the duty of lawyers to assist in the speedy and efficient administration of justice.
• City Sheriff, Iligan City vs. Fortunado, 288 SCRA 190, March 27, 1998 — Cited in connection with the proposition that the lawyer's duty of assisting in the speedy and efficient administration of justice is more significant than that of acquitting their client.
• Far Eastern Shipping Company vs. Court of Appeals, 297 SCRA 30, October 1, 1998 — Cited for the obligation of lawyers to observe the rules of procedure in good faith and not to misuse them to defeat the ends of justice.

• Section 2, Rule 118, 2000 Rules of Criminal Procedure — Provides that all agreements or admissions made or entered into during the pre-trial conference shall be reduced in writing and signed by the accused and counsel, otherwise they cannot be used against the accused, and that agreements covering the matters referred to in Section 1 shall be approved by the court. The Court construed this provision as requiring only two conditions for a pre-trial agreement to bind the accused — that it be in writing and signed by both the accused and their counsel — and held that the court's approval is not needed to make the stipulations binding.
• Section 1, Rule 118, 2000 Rules of Criminal Procedure — Mandates a pre-trial conference in all criminal cases cognizable by the Sandiganbayan, Regional Trial Court, Metropolitan Trial Court, Municipal Trial Court in Cities, Municipal Trial Court, and Municipal Circuit Trial Court, after arraignment and within thirty (30) days from the date the court acquires jurisdiction over the person of the accused, to consider, among other matters, the stipulation of facts. The Court cited this provision to establish that the Rules expressly authorize and encourage stipulations of facts in criminal cases.
• Section 3, Rule 118, Revised Rules of Criminal Procedure — Provides that if the counsel for the accused and/or the prosecutor do not appear at the pre-trial and do not offer an acceptable excuse for their lack of cooperation, the court may impose proper sanctions or penalties. The Court cited this provision in discussing the active roles required of parties and counsel during pre-trial.
• Section 3(e), RA No. 3019, as amended — The anti-graft statute under which petitioners were charged in one of the Informations filed before the Sandiganbayan.
• Article 217, in relation to Article 171, Revised Penal Code — The provisions penalizing malversation through falsification, under which petitioners were charged in two counts.

• Justice Puno (Chairman)
• Justice Sandoval-Gutierrez
• Justice Corona
• Justice Carpio-Morales