People v. Mejares
REITERATIONFacts
The Antecedents: Fifty-nine persons were prosecuted for sedition with murder committed on May 4, 1947, in Tanauan, Leyte. The information was later amended to include twelve accused, among whom were the herein appellants. Procedural History: On February 25, 1949, Atty. Fernando Sudario was appointed attorney de oficio for some of the accused. He moved for a postponement of the trial on the ground that he was not prepared, as the affidavits of prosecution witnesses were not attached to the record. The trial court denied this motion and proceeded with the trial, subsequently rendering a judgment of conviction against the appellants for sedition with murder. The Petition: The appellants appealed the judgment of the Court of First Instance of Leyte, contending that they were denied time to prepare for trial. The Solicitor General agreed with this contention.
Issue(s)
Whether the appellants were denied their right to prepare for trial. Whether the denial of the motion for postponement constitutes a reversible error.
Ruling
The appealed judgment is set aside and the case is remanded to the trial court for further proceedings, for the reception of such additional evidence as the interest of justice may require, and for the rendition thereafter of the corresponding judgment.
Ratio Decidendi
On Whether the appellants were denied their right to prepare for trial: The Court found that the appellants' counsel, Atty. Fernando Sudario, was appointed attorney de oficio on the very day of the arraignment and immediately moved for a postponement, stating his unpreparedness due to the absence of prosecution witness affidavits. Although the trial court denied the motion, the fact remained that the defense counsel was not ready for trial. The Court emphasized that under Section 7 of Rule 114 of the Rules of Court, after a plea of not guilty, a defendant is entitled to at least two days to prepare for trial, unless the court for good cause shown allows further time. This requirement is mandatory. On Whether the denial of the motion for postponement constitutes a reversible error: The Court held that the denial of the right to at least two days to prepare for trial is a reversible error and a ground for a new trial, citing established jurisprudence and commentary on the Rules of Court. The mandatory nature of this provision means that its violation warrants a reversal of the judgment. Therefore, the trial court's denial of the motion for postponement, which effectively deprived the appellants of their statutory right to prepare for their defense, was a reversible error. Consequently, the judgment rendered after such denial must be set aside.
Main Doctrine
The denial of an accused's right to at least two days to prepare for trial, as mandated by Section 7 of Rule 114 of the Rules of Court, constitutes a reversible error and is a ground for a new trial.