People v. Francisco
REITERATIONFacts
The Antecedents: The underlying dispute concerns a criminal case for concubinage filed against private respondents Godofredo Cabahug and Benedicta Ceniza. Procedural History: The prosecution presented its evidence before the Court of First Instance of Davao del Sur. Subsequently, the private respondents filed a demurrer to the evidence. The respondent judge granted this demurrer, acquitting the accused. The People of the Philippines and Lucia Basan, the petitioners, are now seeking to set aside this decision. The Petition: The petitioners filed a petition to set aside the acquittal, arguing that they were denied due process because the demurrer to the evidence did not include a notice of hearing. They also contend that evidence mentioned in their opposition to the demurrer should have been considered. The Supreme Court, however, found no denial of due process as the petitioners were furnished a copy of the demurrer and filed an opposition, and the additional evidence was not formally presented. Furthermore, reopening the case would subject the private respondents to double jeopardy.
Issue(s)
Whether the petitioners were denied due process due to the absence of a notice of hearing on the demurrer to evidence. Whether the respondent judge erred in not considering the evidence mentioned in the petitioners' Opposition to the demurrer.
Ruling
The petition is dismissed for lack of merit. The Court found no denial of due process and upheld the acquittal of the private respondents.
Ratio Decidendi
On the issue of denial of due process due to absence of notice of hearing on the demurrer to evidence: The Court held that the claim of denial of due process was without basis. While it was true that the Demurrer to Evidence did not have a notice of hearing, the petitioners were furnished a copy thereof and, in fact, filed an Opposition. This act of filing an opposition demonstrated their awareness of the demurrer and provided them an opportunity to be heard, thus satisfying the requirements of due process. The Court emphasized that mere absence of a formal notice of hearing does not automatically equate to a violation of due process, especially when the party concerned was otherwise informed and participated in the proceedings. On the issue of the respondent judge not considering evidence mentioned in the Opposition: The Court ruled that the petitioners were not denied due process when the respondent judge did not consider the evidence mentioned in the Opposition to the demurrer. This was because such evidence was not formally presented during the proceedings. The Court reiterated the principle that for evidence to be considered by a court, it must be formally offered and admitted. Evidence merely mentioned in pleadings or oppositions, without formal presentation, cannot be given weight or consideration in the decision-making process. Therefore, the respondent judge acted correctly in not giving any probative value to the unpresented evidence.
Main Doctrine
A claim of denial of due process due to the absence of a notice of hearing on a demurrer to evidence is without basis if the petitioners were furnished a copy of the demurrer and filed an opposition thereto. Furthermore, evidence not formally presented cannot be considered.