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SPS. REUBEN DELA CRUZ v. RAMON C. PAPA IV

FACTS:

The Intestate Estate of Angela M. Butte filed an action for cancellation of titles, recovery of properties, and damages against several defendants, including the Dela Cruzes. The Estate presented its witness, Myron Papa, who testified on the substance of the complaint. However, before the defendants could cross-examine Myron, he passed away due to illness. The Estate sought several postponements to allow Myron to undergo treatment, and eventually filed a motion for the defendants to cross-examine him by deposition. The Regional Trial Court (RTC) granted the motion but Myron died before the deposition could take place. The defendants moved to expunge Myron's testimony, and the Dela Cruzes moved to dismiss the case for failure to prosecute. The RTC denied both motions based on the Estate's lack of control over the delay. On a later date, the RTC struck out Myron's testimony due to the Estate's fault, depriving the defendants of the opportunity to cross-examine him.

ISSUES:

  1. Whether or not the CA erred in reinstating the testimony of Myron C. Papa after the RTC ordered it stricken out for depriving the defendants of the opportunity to cross-examine him.

RULING:

The Supreme Court GRANTS the petition, SETS ASIDE the decision and resolution of the Court of Appeals, and REINSTATES the order of the Regional Trial Court of Antipolo City which struck out Myron's testimony. The Court ruled that the CA's decision to reinstate Myron's testimony was erroneous because the defendants were deprived of the opportunity to cross-examine him due to circumstances beyond their control.

PRINCIPLES:

  • Right to Cross-Examine The right of the adverse party to cross-examine a witness presented by the other party is a fundamental aspect of due process.

  • Timeliness of Objections Objections to the admissibility of evidence must be made at the earliest opportunity or they may be deemed waived.

  • Control Over Proceedings When unexpected circumstances, such as a witness falling ill, delay legal proceedings, it is primarily the responsibility of the party who presented the witness to mitigate such delays.

  • Admissibility of Evidence Testimony that has not been subject to cross-examination is considered incomplete and may be stricken out, thus rendering any evidence authenticated through such testimony inadmissible unless properly rectified.