People v. Pulido
REITERATIONFacts
The Antecedents: Reynaldo Pulido y Fojas was charged and tried in the Court of First Instance of Manila for bribery and falsification of a private document. He was convicted of bribery and acquitted of falsification. Procedural History: The Court of Appeals affirmed the judgment of the trial court. After the Supreme Court rejected his petition for certiorari (G.R. No. L-27490), Pulido petitioned the Court of Appeals for a new trial based on alleged newly discovered evidence: (a) the special division of the Court of Appeals that affirmed his conviction was illegally constituted due to the disqualification of Justices Lucero and Esguerra, and (b) a letter from Frisco Panganiban claiming he (Panganiban) received the bribe money. The Court of Appeals denied this petition for new trial, with Justices Gatmaitan and Cañizares dissenting. The Petition: Pulido resorted to the Supreme Court for the second time, insisting he was entitled to a new trial.
Issue(s)
Whether Justices Lucero and Esguerra of the Court of Appeals were disqualified to sit in the case. Whether the letter from Frisco Panganiban constitutes newly discovered evidence warranting a new trial.
Ruling
The Supreme Court affirmed the order of the Court of Appeals denying Reynaldo Pulido's motion for new trial, with costs against the appellant.
Ratio Decidendi
On the disqualification of Justices Lucero and Esguerra: The Court found no merit in the argument that Justice Lucero was disqualified. The Court noted that any intervention or interest of the attorneys involved ceased when their client, Geroche, became a prosecution witness and was discharged, rendering it immaterial to them or Justice Lucero whether Geroche's testimony was believed. The appearance of these attorneys could not induce bias in Justice Lucero when he voted to affirm Pulido's conviction. Similarly, the Court found no basis for disqualifying Justice Esguerra. His participation in an administrative investigation of Pulido for peculation while employed in the Central Bank was deemed irrelevant to the criminal case prosecuted by the City Fiscal. His opinion in that administrative matter was advisory to the President at most and did not constitute a ground for judicial disqualification, citing precedent from the Emergency Powers Cases. The Court also emphasized that Pulido admitted no legal grounds for disqualification under the first paragraph of Rule 137 and that the justices' discretion in refusing to inhibit themselves was entitled to respect. The Court further stated that while it could order a new trial if a fair and impartial review was not given due to bias, Pulido failed to show any such prejudice. The concurrence of other justices in the affirmance indicated that Justices Esguerra and Lucero were not swayed by prejudice. On the alleged newly discovered evidence: The Court held that the letter from Frisco Panganiban did not constitute adequate ground for a new trial. The Solicitor General argued, and the Court agreed, that the weight of this evidence was "practically nil" because it came from a "polluted source." The Court reasoned that Panganiban, who was asking Pulido for a favor (employment for his children), had a strong propensity to prevaricate to ingratiate himself. Furthermore, the Court questioned why a state witness would give a substantial amount of money to a "total stranger" like Panganiban, whose connection or influence among Central Bank officials was not shown. The Court concluded that Panganiban's testimony, even if admitted, was "valueless" and could not prevail over the positive evidence and corroboration presented by the prosecution, particularly the testimony of State witness Evilio Geroche that he gave the bribe money directly to petitioner Reynaldo Pulido.
Main Doctrine
A motion for new trial based on newly discovered evidence will not prosper if the evidence is merely impeaching in nature, comes from a polluted source, or is otherwise valueless and cannot prevail over positive evidence.