The Supreme Court of the Philippines ruled that a motion to reopen a case based on newly discovered evidence must meet strict requirements, particularly showing that the evidence could not have been discovered with reasonable diligence during the original trial. This ruling emphasizes the importance of thorough preparation and presentation of evidence during the initial trial phase, as the courts are generally reluctant to grant new trials based on information that could have been previously obtained.

Aquino-Galman Case: Can ‘New’ Forensic Evidence Overturn a Final Verdict?

The petitioners, convicted for the double murder of Senator Benigno Aquino, Jr. and Rolando Galman, sought to reopen their case based on a forensic report and an eyewitness testimony that they claimed were newly discovered. The central legal question was whether this evidence met the stringent requirements for a new trial under Rule 121 of the 2000 Rules of Criminal Procedure, specifically regarding the diligence in discovering and presenting such evidence.

The Supreme Court addressed the motion to re-open the case, focusing on the petitioners’ claim of newly discovered evidence. The Court emphasized that new trials are disfavored and granted cautiously, requiring strict adherence to the criteria outlined in the Rules of Court. A critical aspect of the Court’s analysis was whether the evidence presented was genuinely “newly discovered” and if the petitioners had exercised due diligence in seeking it during the initial trial.

Section 2. Grounds for a new trial. — The court shall grant a new trial on any of the following grounds:

(b) That new and material evidence has been discovered which the accused could not with reasonable diligence have discovered and produced at the trial and which if introduced and admitted would probably change the judgment.

The Court scrutinized the forensic report submitted by the petitioners, noting that it was based on materials and methods that were available during the original trial. The forensic group’s report, while offering a different interpretation of the evidence, did not introduce any new physical evidence that could not have been obtained earlier. Thus, the Court found that the report did not meet the criteria for newly discovered evidence, as the petitioners failed to demonstrate that they could not have secured an independent forensic study during the trial.

Furthermore, the Supreme Court examined the testimony of the alleged eyewitness, SPO4 Ruben M. Cantimbuhan, who claimed to have seen a man in blue uniform shooting Senator Aquino. The Court found this testimony to be merely corroborative of other defense witnesses’ accounts presented during the trial. Since the Sandiganbayan had already assessed and discredited these accounts in favor of the prosecution’s eyewitnesses, the new testimony was unlikely to alter the court’s decision. The Court reiterated that new trials are not granted if the new evidence is merely cumulative, corroborative, or impeaching.

The Court also dismissed the petitioners’ claim of inadequate legal assistance, noting that Atty. Rodolfo U. Jimenez, an experienced criminal lawyer, had vigorously defended the petitioners throughout the trial and subsequent appeals. The Court found no evidence to support the claim that Atty. Jimenez had been remiss in his duties, emphasizing that clients are generally bound by the actions of their counsel in the conduct of their case. The Supreme Court cited People vs. Umali, highlighting that mistakes made by counsel due to ignorance or incompetence do not typically warrant a new trial.

In criminal as well as civil cases, it has frequently been held that the fact that blunders and mistakes may have been made in the conduct of the proceedings in the trial court, as a result of the ignorance, inexperience, or incompetence of counsel, does not furnish a ground for a new trial.

The Supreme Court also addressed the petitioners’ assertion that the forensic evidence may have been manipulated, finding the claim unsubstantiated and speculative. Without concrete facts to support the allegation, the Court dismissed it as unfounded.

In conclusion, the Supreme Court denied the motion to reopen the case, emphasizing the importance of due diligence in presenting evidence during the initial trial and the strict requirements for granting a new trial based on newly discovered evidence. This decision reinforces the principle that final judgments should not be easily overturned unless there is a clear showing of evidence that could not have been previously obtained with reasonable effort.

FAQs

What was the key issue in this case?	The key issue was whether the petitioners were entitled to a new trial based on newly discovered evidence, specifically a forensic report and an eyewitness testimony, under Rule 121 of the 2000 Rules of Criminal Procedure. The court focused on whether this evidence could have been discovered with reasonable diligence during the original trial.
What is required for evidence to be considered “newly discovered”?	For evidence to be considered newly discovered, it must have been discovered after the trial, it could not have been discovered and produced at trial even with reasonable diligence, it must be material and not merely cumulative or impeaching, and it must be of such weight that it would probably change the judgment if admitted.
What does “due diligence” mean in the context of discovering evidence?	“Due diligence” means that the party seeking a new trial must have acted reasonably and in good faith to obtain the evidence before or during the trial. This involves a timely and diligent effort to gather evidence, given the totality of circumstances and facts known to the party.
Why was the forensic report not considered newly discovered evidence?	The forensic report was not considered newly discovered because it was based on materials and methods that were available during the original trial. The petitioners failed to demonstrate that they could not have obtained an independent forensic study during the trial with reasonable diligence.
Why was the eyewitness testimony not considered sufficient for a new trial?	The eyewitness testimony was not considered sufficient because it was merely corroborative of other defense witnesses’ accounts that had already been presented and discredited during the trial. New trials are not granted if the new evidence is merely cumulative or corroborative.
What was the Court’s view on the petitioners’ claim of inadequate legal assistance?	The Court dismissed the claim of inadequate legal assistance, noting that the petitioners were represented by an experienced criminal lawyer who vigorously defended their cause throughout the trial and appeals. There was no evidence to support the claim that the lawyer had been remiss in his duties.
What is the significance of the “Berry” rule in this case?	The “Berry” rule, derived from Berry vs. State of Georgia, outlines the standards for granting a new trial based on newly discovered evidence. It requires that the evidence has come to the applicant’s knowledge since the trial, that it was not due to a lack of diligence, that it is material, and that it is not merely cumulative.
Can a final judgment be easily overturned based on new evidence?	No, final judgments are not easily overturned. Courts require a clear showing of evidence that could not have been previously obtained with reasonable effort.

This case underscores the stringent requirements for reopening a case based on newly discovered evidence, emphasizing the need for thorough preparation and presentation of evidence during the initial trial. The decision highlights the balance between ensuring justice and respecting the finality of judgments.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: BRIG. GEN. LUTHER A. CUSTODIO VS. SANDIGANBAYAN AND PEOPLE OF THE PHILIPPINES, G.R. NOS. 96027-28, March 08, 2005