Manois v. De la Cruz
REITERATIONFacts
The Antecedents: Petitioner Cirilo Manaois was charged with murder in Criminal Case No. L-1817 before the Court of First Instance of Pangasinan, Branch IV. The information was filed on June 30, 1965. Procedural History: On October 27, 1965, petitioner wrote to the respondent Judge requesting the appointment of assessors pursuant to Section 154 of Act No. 190. The prosecution filed a memorandum in opposition. On November 24, 1965, the respondent Judge denied the request, citing that the request was not made at the earliest convenient time, considering the arraignment on July 13, 1965, the initial trial setting for September 7-9, 1965 (postponed upon petitioner's motion due to alleged sickness to October 28-29, 1965), and the request for assessors being filed only on October 27, 1965, one day before the rescheduled hearing. The Petition: Petitioner moved for reconsideration, which was denied. He then instituted the instant petition for certiorari with preliminary injunction, questioning whether the respondent Judge acted without or in excess of jurisdiction, or with grave abuse of discretion in denying the request for assessors.
Issue(s)
Whether the respondent Judge acted without or in excess of jurisdiction, or with grave abuse of discretion in denying petitioner's request for the appointment of assessors. Whether the request for the appointment of assessors was made at the earliest convenient time.
Ruling
The petition is dismissed. The respondent Judge did not act without or in excess of jurisdiction, nor with grave abuse of discretion.
Ratio Decidendi
On the issue of whether the respondent Judge acted without or in excess of jurisdiction, or with grave abuse of discretion in denying petitioner's request for the appointment of assessors: The Court held that the question should be answered in the negative. The right to the service of assessors is explicitly made subject to the condition that the request for their appointment must be made "at the earliest convenient time so as not to hinder or delay the trial or to unnecessarily inconvenience the progress of the work of the Court." In the present case, the petitioner was arraigned on July 13, 1965, and the trial was initially set for September 7, 8, and 9, 1965, by choice of the parties. The hearing was subsequently postponed to October 28 and 29, 1965, upon the petitioner's motion alleging sickness. It was only on October 27, 1965, one day before the rescheduled hearing, that the petitioner filed his request for assessors, which was more than three months after his arraignment and despite being represented by counsel since the beginning. Under these circumstances, the respondent Judge had sufficient reason to believe that the request was not seasonably made and was potentially intended for purposes of delay. The Court stated that it was not prepared to say that the Judge committed an abuse, let alone a grave abuse, of discretion that would warrant correction by certiorari. On the issue of whether the request for the appointment of assessors was made at the earliest convenient time: The Court found that the timeline of events clearly indicated that the request was not made at the earliest convenient time. The petitioner had ample opportunity to request for assessors from the time of his arraignment until the scheduled hearings. The delay in filing the request, particularly one day before the rescheduled trial, strongly suggested that it was not made in good faith and was likely intended to impede the proceedings. The Court reiterated that the statutory requirement for making such a request at the "earliest convenient time" is a crucial safeguard against undue delays in the administration of justice. The respondent Judge's order correctly applied this principle by considering the petitioner's actions and the overall progress of the case.
Main Doctrine
The right to the service of assessors is subject to the condition that the request for their appointment must be made at the earliest convenient time so as not to hinder or delay the trial or unnecessarily inconvenience the progress of the work of the Court. A request made one day before the scheduled hearing, after the case has been pending for several months and the accused has been arraigned, may be considered as not seasonably made and potentially for purposes of delay, justifying the denial of the request by the trial court.