Maliwat v. CA

G.R. No. 107041-42 (May 15, 1996)

Facts:

Feliciano Maliwat was charged with falsification of public documents in two separate informations filed before the Court of First Instance (CFI) of Cavite, Branch 3, on November 18, 1977. The first information (Criminal Case No. 158-77) alleged that Maliwat unlawfully filled out a blank form of a transfer certificate of title (TCT) to make it appear as if he was the registered owner of a parcel of land, despite knowing that the land was already registered under the name of Green Valley Realty Corporation. The second information (Criminal Case No. 159-77) involved similar allegations concerning another parcel of land.

Maliwat was arraigned on August 2, 1978, and pleaded not guilty. The trial commenced, but the proceedings were marked by numerous postponements, largely due to Maliwat's absences. The trial court eventually rendered a decision on February 12, 1986, convicting Maliwat of the charges and sentencing him to an indeterminate prison term and fines.

The prosecution's evidence included testimonies from Atty. Milagros Santiago, the acting Register of Deeds, who became suspicious of the titles presented by Maliwat due to apparent forgeries. Atty. Santiago referred the matter to the National Bureau of Investigation (NBI), which conducted an investigation revealing that the titles were indeed falsified. Atty. Escolastico Cuevas, the former Register of Deeds, testified that his signature on the titles was forged.

Maliwat, on the other hand, claimed that he had purchased the land from Benigno T. Aseo and that the titles he presented were genuine. He argued that he had been in possession of the land and had paid taxes on it. However, he failed to provide original documents to support his claims and could not adequately explain the discrepancies in the title numbers.

After a lengthy trial, the Regional Trial Court convicted Maliwat, and the Court of Appeals affirmed the conviction. Maliwat subsequently filed a petition for review, raising issues regarding due process and the alleged bias of the trial judge, who had previously served as a prosecution witness.

Legal Issues:

1. Whether Feliciano Maliwat was denied his right to due process during the trial.
2. Whether the trial judge's prior testimony as a prosecution witness constituted grounds for a mistrial.
3. Whether the evidence presented was sufficient to prove Maliwat's guilt beyond a reasonable doubt.

Arguments:

• Petitioner (Maliwat):

  • Argued that he was denied due process due to the trial judge's prior involvement as a prosecution witness, which he claimed created a bias against him.
  • Contended that the evidence presented by the prosecution was insufficient to establish his guilt, asserting that he had legitimate ownership of the properties in question.

• Respondents (Prosecution):

  • Maintained that Maliwat received a fair trial, highlighting that he had ample opportunity to present his case and that the trial judge exhibited leniency towards him.
  • Asserted that the evidence, including testimonies from credible witnesses and the findings of the NBI, sufficiently proved that the documents were falsified and that Maliwat was the author of the falsification.

Court's Decision and Legal Reasoning:

The Supreme Court denied Maliwat's petition for review, affirming the decision of the Court of Appeals and the Regional Trial Court. The Court found that Maliwat was not denied due process, noting that he had actively participated in the trial and had the opportunity to present his defense. The numerous postponements and absences were attributed to his own actions, which undermined his claim of being denied a fair trial.

Regarding the alleged bias of the trial judge, the Court ruled that the judge's previous testimony did not disqualify him from presiding over the case. The judge's role as a witness was limited to factual matters related to his duties as Clerk of Court, and there was no evidence of prejudgment or bias in his conduct during the trial.

The Court also concluded that the evidence presented by the prosecution was compelling. The testimonies of Atty. Santiago and Atty. Cuevas, along with the findings of the NBI, established that the titles were falsified. The Court emphasized the principle that possession of a forged document raises a presumption of guilt against the possessor, which applied to Maliwat in this case.

Significant Legal Principles Established:

1. The right to due process is upheld when a defendant is given a fair opportunity to present their case, even if there are delays or absences attributed to the defendant.
2. A judge's prior testimony as a witness does not automatically disqualify them from presiding over a case, provided there is no evidence of bias or prejudgment.
3. The possession of a forged document creates a presumption of guilt, placing the burden on the possessor to explain the legitimacy of the document.