115. BAYAS VS. SANDIGANBAYAN CRC Law Firm for petitioners.

The Solicitor General for respondents.

VOL. 391, NOVEMBER 12, 2002 415 417
Bayas vs. Sandiganbayan VOL. 391, NOVEMBER 12, 2002 417
G.R. Nos. 143689-91. November 12, 2002.* Bayas vs. Sandiganbayan
SIXTO M. BAYAS and ERNESTO T. MATUDAY, petitioners, vs. THE PANGANIBAN, J.:
SANDIGANBAYAN (FIRST DIVISION), THE PEOPLE OF THE PHILIPPINES and May pre-trial stipulations duly signed by the accused and their counsel be unilaterally
THE OFFICE OF THE SPECIAL PROSECUTOR, respondents. withdrawn before the commencement of the trial? To this main issue, the answer is
Criminal Procedure; Pre-trial; The new Rules on Criminal Procedure mandate “No.” Stipulations freely and voluntarily made are valid and binding and will not be set
parties to agree on matters of facts, issues and evidence.—Petitioners fail to appreciate aside unless for good cause. The Rules of Court mandate parties in a criminal case to
the indispensable role of stipulations in the speedy disposition of cases. The new Rules stipulate facts. Once they have validly and voluntarily signed the stipulations, the
on Criminal Procedure mandate parties to agree on matters of facts, issues and accused and their counsel may not set these aside on the mere pretext that they may
evidence. Such stipulations are greatly favored because they simplify, shorten or settle be placed at a disadvantage during the trial.
litigations in a faster and more convenient manner. They save costs, time and Statement of the Case
resources of the parties and, at the same time, help unclog court dockets. Before us is a Petition for Certiorari under Rule 65 of the Rules of Court, praying for the
_______________ setting aside of the April 28, 20001 and the May 26, 20002 Orders of the
* THIRD DIVISION. Sandiganbayan3 (SBN) in Criminal Case Nos. 25280-82. The first Order denied
416 petitioners’ Motion to Withdraw the Joint Stipulation of Facts and Documents, 4 while
416 SUPREME COURT REPORTS ANNOTATED the second denied reconsideration.5
Bayas vs. Sandiganbayan The Facts
Same; Same; Once validly entered into, stipulations will not be set aside unless On May 6, 1999, three Informations6 were filed before the SBN, charging Petitioners
for good cause; The party who validly made them can be relieved therefrom only upon Ernesto T. Matuday and Sixto M. Bayas with violation of Section 3(e) of c, as amended;
a showing of collusion, duress, fraud, misrepresentation as to facts and undue influence and two counts of malversation through falsification penalized under Article 217, in
or upon a showing of sufficient cause on such terms as will serve justice in a particular relation to Article 171, of the Revised Penal Code. They were charged in their capacities
case.—Once validly entered into, stipulations will not be set aside unless for good as municipal mayor and municipal treasurer, respectively, of the Municipality of
cause. They should be enforced especially when they are not false, unreasonable or Kabayan, Province of Benguet.
against good morals and sound public policy. When made before the court, they are _______________
1 Rollo, p. 27.
conclusive. And the party who validly made them can be relieved therefrom only upon
2 Id., pp. 28-29.
a showing of collusion, duress, fraud, misrepresentation as to facts, and undue
3 First Division. Signed by Justice Francis E. Garchitorena (Division chairman) and
influence; or upon a showing of sufficient cause on such terms as will serve justice in
a particular case. Moreover, the power to relieve a party from a stipulation validly made Justices Catalino R. Castañeda, Jr. and Gregory S. Ong (members).
4 Rollo, pp. 45-48.
lies in the court’s sound discretion which, unless exercised with grave abuse, will not
5 Id., pp. 49-52.
be disturbed on appeal.
6 Records, pp. 224-229.
Same; Same; Parties are bound by the action or the inaction of their counsel;
The rule extends even to the mistakes and the simple negligence committed by the 418
counsel.—Moreover, it is hornbook doctrine that parties are bound by the action or the 418 SUPREME COURT REPORTS ANNOTATED
inaction of their counsel. To all intents and purposes, the acts of a lawyer in the defense Bayas vs. Sandiganbayan
or the prosecution of a case are the acts of the client. The rule extends even to the During their arraignment on September 21, 1999, petitioners pled “not guilty.” The
mistakes and the simple negligence committed by the counsel. pretrial conference scheduled on October 15, 1999 was cancelled and reset to
Same; Same; Conditions for a pre-trial agreement to be binding on the November 5, 1999, because the counsel for the accused, Atty. Jose M. Molintas, was
accused.—Based on the foregoing provision, for a pre-trial agreement to be binding on not prepared.7 On November 5, 1999, the pretrial was again cancelled because of the
the accused, it must satisfy the following conditions: (1) the agreement or admission absence of Atty. Molintas, who was allegedly “suffering from the flu.” Nonetheless, the
must be in writing, and (2) it must be signed by both the accused and their counsel. Sandiganbayan urged the accused to discuss with their counsel the stipulation of facts
The court’s approval, mentioned in the last sentence of the above-quoted Section, is drafted by Ombudsman Prosecutor II Evelyn T. Lucero. They were asked to do so, so
not needed to make the stipulations binding on the parties. Such approval is necessary that at the resumption of the pretrial on December 10, 1999, they could expeditiously
merely to emphasize the supervision by the court over the case and to enable it to pass upon all other matters that still remained to be resolved. 8
control the flow of the proceedings. On December 10, 1999, the parties submitted a “Joint Stipulation of Facts and
SPECIAL CIVIL ACTION in the Supreme Court. Certiorari. Documents,” which had been duly signed by the two accused (herein petitioners), Atty.
The facts are stated in the opinion of the Court. Molintas and Prosecutor Lucero. It is reproduced hereunder:

Page 1 of 5
 “JOINT STIPULATION OF FACTS AND DOCUMENTS ‘H-1-a’ ‘8-a-1’ Signature of accused Mayor Matuday at the
“COME NOW the accused, counsel for the accused and the Prosecution, by and Dorsal portion of Check No. 60915-S-1
through the undersigned Special Prosecution Officer, Office of the Special Prosecutor, ‘Criminal Cases
unto the Honorable Court, most respectfully aver: THAT— Nos. 25282-
1. “1.After a conference the Defense and the Prosecution admitted the following 25280
facts as follows: ‘I’ ‘a’ Check No. 609177 for P55,000.00 dated June
1. “a.Accused Ernesto Matuday was then the Municipal Mayor and accused 28, 1995 signed by Mayor Matuday and
Sixto Bayas was and [is] still the Municipal Treasurer and designated Treasurer Bayas
Municipal Accountant both of Kabayan, Benguet during the period relevant ‘I-1’ ‘9-a’ Dorsal portion of Check No. 609177
to this case; ‘I-1-a’ ‘9-a-1’ Signature of Yolanda Millanes
2. “b.Both of the accused admit the disbursement of the amount of P510,000.00 420
and P55,000.00. 420 SUPREME COURT REPORTS ANNOTATED
1. “2.The Prosecution and Defense jointly admit the following documents as their Bayas vs. Sandiganbayan
respective documentary exhibits x x x ([with] reservation to mark additional ‘I-1-b’ ‘9-a-2’ Signature of Mayor Matuday
exhibits during the trial of the case) as follows: ‘J’ ‘10’ Undated Disbursement Voucher for P55,000.00
_______________ “3. The Defense shall present at least four witness while the Prosecution opts not to
7 Sandiganbayan Order dated October 15, 1999; Records, p. 77.
present any witness considering that Defense admitted all the documentary evidence
8 Sandiganbayan Order dated November 5, 1999; id., p. 67.
of the Prosecution.
419 “Quezon City, December 10, 1999.
VOL. 391, NOVEMBER 12, 2002 419 (signed) (signed)
Bayas vs. Sandiganbayan ATTY. JOSE M. MOLINTAS ATTY. EVELYN TAGUBA LUCERO
‘For the Exhibitsfor Description Counsel for Accused Ombudsman Prosecutor II
Prosecution theDefense (signed) (signed)
Common Exhibits SIXTO BAYAS ERNESTO MATUDAY
‘A’ ‘1’ COA Report dated February 29, 1996 Accused Accused”9
‘B’ ‘2’ COA Memorandum Dated September 25, On January 14, 2000, the pre-trial conference was again scuttled due to the absence
1996 of Atty. Molintas. The hearing was rescheduled for February 14, 2000. However, on
‘C’ ‘3’ Page of journal entry of the Office of the February 7, 2000, he moved to withdraw as counsel for the accused. His motion was
Municipal Accountant granted by the anti-graft court in an Order dated February 14, 2000. In the same Order,
‘D’ ‘4’ Resolution No. 138 of the Sangguniang Bayan the pretrial was rescheduled for March 31, 2000, to give the accused ample time to
of the Municipality of Kabayan Benguet employ a new counsel.
carried on August 15, 1996 On April 26, 2000, the accused, represented by their new counsel, Atty. Cecilia M.
‘E’ ‘5’ Transcript of the [S]tenographic Notes taken Cinco, moved to withdraw the Joint Stipulation of Facts and Documents. Specifically,
during the closed door session of the they sought to withdraw, first, Stipulation 1(b) which states that “Both the accused admit
Sangguniang Bayan[,] Kabayan, Benguet on the disbursement of the amount of P510,000.00 and P55,000.00”; and second, Exhibits
August 15, 1996 at 1:50 P.M. “1” to “8-a”. They invoked their constitutional right to be presumed innocent until proven
‘F’ ‘6’ Result of the Statement of Investigation guilty.
conducted on March 24, 1997 Ruling of the Sandiganbayan
‘For Criminal The Sandiganbayan justified its denial of petitioners’ Motion to Withdraw Joint
Cases Nos. Stipulation of Facts and Documents in this wise:
25280-25281 _______________
‘G’ ‘7’ Undated disbursement Voucher No. 401- 9 Rollo, pp. 41-43.

9505186 For the payment of Mobilization fee 421

for the various Projects at Kabayan, Benguet VOL. 391, NOVEMBER 12, 2002 421
For P510,000.00 Bayas vs. Sandiganbayan
‘H’ ‘8’ Check No. 60915S-1 for P510,000.00 dated “x x x. [For] the fact that there [was] express statement from Atty. Rogelio A. Cortes this
May 4, 1995 signed by both Accused Mayor morning that neither fraud nor any other mistake of a serious character vitiated the
Matuday and Treasurer Bayas consent of the parties when they affixed their conformity to the stipulations of facts, the
‘H-1’ ‘8-a’ Dorsal portion of Check No. 60915 S-1 reason put forth by the accused or movant’s counsel at this time, is that if these

Page 2 of 5
stipulations were to remain, then the accused might as well not present any evidence Petitioners fail to appreciate the indispensable role of stipulations in the speedy
on the entire accusation against him as this will already be supported by the evidence disposition of cases. The new Rules on Criminal Procedure mandate parties to agree
on record. While the court, indeed, sees this as a possibility, that, by itself, is not a on matters of facts, issues and
ground for withdrawing any stipulation freely and knowingly made and given.” 10 _______________
13 Petitioners’ Memorandum, p. 12; Rollo, p. 128: Original in upper case.
In the second assailed Order, the anti-graft court denied reconsideration and reiterated
its previous stand, as follows: 423
“x x x. The fact that the stipulation of facts leaves less or no room for the accused to VOL. 391, NOVEMBER 12, 2002 423
defend himself is not a ground for setting aside a pre-trial order; in fact, an accused can Bayas vs. Sandiganbayan
plead guilty if he so desires or make admissions as he deems appropriate and truthful, evidence. Such stipulations are greatly favored because they simplify, shorten or settle
even if in the mind of the new counsel, it gave very few opportunities to present litigations in a faster and more convenient manner. They save costs, time and
contesting evidence.”11 resources of the parties and, at the same time, help unclog court dockets.
It then added that “the pre-trial order shall remain. The admissions therein contained Once validly entered into, stipulations will not be set aside unless for good
can be used in this case and for whatever purpose the Rules on Evidence will allow.” cause.14 They should be enforced especially when they are not false, unreasonable or
Hence, this Petition.”12 against good morals and sound public policy.15 When made before the court, they are
The Issues conclusive. And the party who validly made them can be relieved therefrom only upon
In their Memorandum, petitioners raise the following issues for the Court’s a showing of collusion, duress, fraud, misrepresentation as to facts, and undue
consideration: influence;16 or upon a showing of sufficient cause on such terms as will serve justice in
_______________ a particular case.17 Moreover, the power to relieve a party from a stipulation validly
10 Assailed Order dated April 28, 2000; Rollo, p. 27-A.
made lies in the court’s sound discretion which, unless exercised with grave abuse, will
11 Assailed Order dated May 26, 2000, p. 1; id., p. 28.
not be disturbed on appeal.18
12 The case was deemed submitted for decision on May 10, 2001, upon this Court’s
Validity of the Joint Stipulations
receipt of petitioners’ Memorandum, which was signed by Attys. Rogelio A. Cortes and While petitioners wish to be relieved from the stipulations, they, however, do not allege
Cecilia L. Cinco of the “CRC Law Firm.” Respondents’ Memorandum, filed on April 25, that these were false or misleading or were obtained through force or fraud. On the
2001, was signed by Attys. Rodrigo V. Coquia and Ireneo M. Paldeng of the Office of contrary, they do not dispute the finding of the anti-graft court that no fraud or serious
the Special Prosecutor/Ombudsman. mistake vitiated their and their counsel’s consent to the signing of these stipulations.
422 They even admitted, in answer to its query, that they had freely given their consent.
422 SUPREME COURT REPORTS ANNOTATED Nonetheless, in a desperate bid to strengthen their position, petitioners lay the
Bayas vs. Sandiganbayan blame on the alleged incompetence of their former counsel. They claim that, in agreeing
“I to the Joint Stipulation, he failed to consider their legal interests.
Whether or not respondent Sandiganbayan committed grave abuse of discretion _______________
amounting to lack or excess of jurisdiction in denying petitioners’ Motion to Withdraw 14
National Council of Knights and Ladies of Security v. Scheiber, 169 NW 272,
the Joint Stipulation of Facts and Documents, considering the relevant facts and October 25, 1918.
15 Esch v. Forster, 168 So. 229, January 20, 1936.
applicable laws and rules.
“II 16 83 CJS 90 (1953).
17 Woods v. First National Bank of Chicago, 41 NE2d 235, April 20, 1942.
Whether or not the denial by respondent Sandiganbayan of the withdrawal of the
18 Ibid.
Joint Stipulation of Facts and Documents would result in manifest injustice and
impairment of the constitutional rights of the petitioners. 424
“III 424 SUPREME COURT REPORTS ANNOTATED
Whether or not there is a law or rule which would bar petitioners from withdrawing Bayas vs. Sandiganbayan
their Joint Stipulation of Facts and Documents from the respondent Sandiganbayan.” 13 To be a ground for relief against a stipulation, a mistake must be one of fact—not, as
Plainly put, the issue raised by petitioners is whether they may be allowed to withdraw in this case, a mere lack of full knowledge of fact because of failure to exercise due
unilaterally from the Joint Stipulation of Facts and Documents. diligence in ascertaining it.19
The Court’s Ruling Moreover, it is hornbook doctrine that parties are bound by the action or the inaction
The Petition has no merit. of their counsel. To all intents and purposes, the acts of a lawyer in the defense or the
Main Issue: prosecution of a case are the acts of the client. The rule extends even to the mistakes
Withdrawal from the Joint Stipulation and the simple negligence committed by the counsel.20
Petitioners contend that pre-trial stipulations may be unilaterally withdrawn by the Presumption of Innocence
accused because allegedly, they are not binding until after the trial court has issued a In their effort to withdraw from the Joint Stipulation, petitioners argue that the two
pre-trial order approving them. We are not persuaded. questioned items impair their constitutional right to be presumed innocent, violate their

Page 3 of 5
 24
right against self-incrimination, and deny them due process in the sense that the trial See People v. Mapa, 20 SCRA 1164, August 30, 1967.
would be a “useless formality, an idle ceremony.”21 25 27 SCRA 512, March 28, 1969.
26 260 SCRA 25, July 30, 1996.
Other than by generalized argumentation, petitioners have not convinced us that
27 Herrera, Remedial Law, Volume IV, 2001 ed., pp. 667-668, citing People v.
the aforementioned constitutional rights would be violated. True, the old Rules of Court
frowned upon stipulations of facts in criminal cases because of a perceived danger— Donato, 198 SCRA 130, 154, June 5, 1991; People v. Hernandez, supra.
that by the mere expedient of stipulating with the defense counsel the elements of the 426
crime charged, the prosecution would relieve itself of its duty to prove the guilt of the 426 SUPREME COURT REPORTS ANNOTATED
accused beyond reasonable doubt.22 However, the Rules were amended in 1985, Bayas vs. Sandiganbayan
precisely to enable parties to stipulate facts. The amendment was carried over to the because the waiver was voluntary, made with the assistance of counsel and is
2000 Revised Rules on Criminal Procedure.23 sanctioned by the Rules on Criminal Procedure.
_______________ Necessity of a Pretrial Order
19 83 CJS 91 (1953).
Petitioners further contend that the law on pretrial requires the issuance of a pretrial
20 Villa Rhecar Bus v. De La Cruz, 157 SCRA 13, January 7, 1988; Legarda v.
order to make pre-trial stipulations binding. We do not agree.
CA, 280 SCRA 642, October 16, 1997. Section 2 of Rule 118 of the Rules of Court states:
21 Petitioners’ Memorandum, p. 24; Rollo, p. 140.
“Sec. 2. Pre-trial agreement.—All agreements or admissions made or entered [into]
22 People v. Hernandez, 260 SCRA 25, July 30, 1996.
during the pre-trial conference shall be reduced in writing and signed by the accused
23 Section 1, Rule 118:
and counsel, otherwise, they cannot be used against the accused. The agreements
“SECTION 1. Pre-trial; mandatory in criminal cases.—In all criminal cases cognizable covering the matters referred to in section 1 of this Rule shall be approved by the
by the Sandiganbayan, Regional Trial Court, Metropolitan Trial Court, Municipal Trial court.”28
Court in Cities, Municipal Trial Court and Municipal Circuit Trial Court, the court shall, Based on the foregoing provision, for a pre-trial agreement to be binding on the
after arraignment and within thirty (30) days from the date accused, it must satisfy the following conditions: (1) the agreement or admission must
425 be in writing, and (2) it must be signed by both the accused and their counsel. The
VOL. 391, NOVEMBER 12, 2002 425 court’s approval, mentioned in the last sentence of the above-quoted Section, is not
Bayas vs. Sandiganbayan needed to make the stipulations binding on the parties. Such approval is necessary
The acceptability of stipulating facts has long been established in our jurisprudence. In merely to emphasize the supervision by the court over the case and to enable it to
a case involving illegal possession of firearms, 24 the prosecution and the defense control the flow of the proceedings.
stipulated the fact that the accused had been found in possession of a gun without the Once the stipulations are reduced into writing and signed by the parties and their
required permit or license. In People v. Bocar,25 the Court considered as valid the counsels, they become binding on the parties who made them. They become judicial
admission by the accused of the existence of certain affidavits and exhibits, which the admissions of the fact or facts stipulated.29 Even if placed at a disadvantageous
prosecution had presented to dispense with oral testimonies on the matter contained position, a party may not be allowed to rescind them unilaterally; it must assume the
therein. In People v. Hernandez,26 which involved illegal recruitment, the Court upheld consequences of the disadvantage.30 If the accused are allowed to plead guilty under
the Joint Stipulation that the accused had not been licensed or authorized by the appropriate circumstances, by parity of reasoning, they should likewise be allowed to
Philippine Overseas Employment Agency to recruit workers for overseas jobs. enter into a fair and true pretrial agreement under appropriate circumstances.
There is nothing irregular or unlawful in stipulating facts in criminal cases. The _______________
policy encouraging it is consistent with the doctrine of waiver, which recognizes that “x 28 2000 Rules of Criminal Procedure.
29 Schreiber v. Rickert, 50 NE 2d 879, October 13, 1943.
x x everyone has a right to waive and agree to waive the advantage of a law or rule
30 See Dequito v. Llamas, 66 SCRA 504, September 4, 1975.
made solely for the benefit and protection of the individual in his private capacity, if it
can be dispensed with and relinquished without infringing on any public right and 427
without detriment to the community at large.”27 VOL. 391, NOVEMBER 12, 2002 427
In the present case, the Joint Stipulation made by the prosecution and petitioners Bayas vs. Sandiganbayan
was a waiver of the right to present evidence on the facts and the documents freely There is another cogent reason why the Joint Stipulation should be binding. It must be
admitted by them. There could have been no impairment of petitioners’ right to be noted that the SBN could not fully act on the matter, not through its fault, but because
presumed innocent, right to due process or right against self incrimination of the continued absence of petitioners’ counsel. Verily, the records reveal that at the
_______________ intended completion of the pre-trial on January 14, 2000, it could not pass upon the
the court acquires jurisdiction over the person of the accused, unless a shorter Joint Stipulation because he was absent. Also, the pretrial conference had to be re-
period is provided for in special laws or circulars of the Supreme Court, order a pre-trial scheduled six times, just to ensure the attendance of the parties and their counsels and
conference to consider the following: to prepare them for the conference.
‘x x x xxx xxx Therefore, under these circumstances, the SBN cannot be faulted for its failure to
‘(b) stipulation of facts; approve expressly the stipulations. It had the opportunity to rule on the matter only
‘x x x xxx x x x’ ”
Page 4 of 5
 36
when the accused, through their new counsel, Atty. Cecilia L. Cinco, moved to withdraw City Sheriff, Iligan City v. Fortunado, 288 SCRA 190, March 27, 1998.
37
their stipulations. In its first assailed Order, the SBN upheld their validity, thereby Far Eastern Shipping Company v. Court of Appeals, 297 SCRA 30, October 1,
effectively approving the submitted Joint Stipulation of Facts and Documents. The 1998.
38
assent of the court to agreements of the parties, assisted by their counsel, is assumed J. Bellosillo, Effective Pre-trial Technique, 1990 ed., p. 199.
until they indicate a dissent.31 Thus, the stipulations freely made by the latter are to be 429
respected as their true will and intention with regard to the facts and evidence of the VOL. 391, NOVEMBER 12, 2002 429
case, especially if the anti-graft court has not struck them down for being violative of Bayas vs. Sandiganbayan
the law. Grave Abuse of Discretion
Role of Lawyers in Pre-trials As already discussed, the power to relieve a party from a stipulation validly made lies
Pre-trial is meant to simplify, if not fully dispose of, the case at its early stage. It is at the sound discretion of the court. Unless exercised with grave abuse, this discretion
therefore important that the parties take active roles in the proceedings. The Rules on will not be disturbed on appeal.39 There is “grave abuse of discretion” where “a power
Criminal Procedure provide that if the counsel for the accused and/or the prosecutor is exercised in an arbitrary, capricious, whimsical or despotic manner by reason of
do not appear at the pre-trial and do not offer an acceptable excuse for their lack of passion or personal hostility, so patent and so gross as to amount to evasion of positive
cooperation, the court may impose proper sanctions or penalties. 32 duty or virtual refusal to perform a duty enjoined by, or in contemplation of law.”40
Verily, during pre-trial, attorneys must make a full disclosure of their positions as to Petitioners in this case failed to prove that the Sandiganbayan committed grave
what the real issues of the trial would be. They should not be allowed to embarrass or abuse of discretion in disallowing them to withdraw the stipulations that they had freely
inconvenience the court or injure the opposing litigant by their careless preparation for and voluntarily entered into. Also, no bad faith or malice was or can be imputed to the
a case; anti-graft court for failing to immediately act upon the Joint Stipulation. The delay was
_______________ due, not to its deliberate evasion of its duty, but to the continued absence of petitioners’
31 McLeod v. Hyman, 116 A. 535, February 6, 1922.
counsel.
32 Section 3, Rule 118 of the Revised Rules of Criminal Procedure.
WHEREFORE, the Petition is DENIED, and the assailed Orders AFFIRMED. Costs
428 against petitioners.
428 SUPREME COURT REPORTS ANNOTATED SO ORDERED.
Bayas vs. Sandiganbayan Puno (Chairman), Sandoval-Gutierrez, Corona and Carpio-Morales,
or by their failure to raise relevant issues at the outset of a trial; or, as in this case, by JJ., concur.
their unilateral withdrawal of valid stipulations that they signed and that their clients fully Petition denied, orders affirmed.
assented to.33 Note.—Pre-trial and its governing rules are not technicalities which the parties may
The records reveal that the parties were the ones who volunteered to make the ignore or trifle with. (Tui vs. Middleton, 310 SCRA 580 [1999])
Joint Stipulation of the facts of the case. ——o0o——
Thus, the anti-graft court can rightfully expect that both parties arrived upon it with _______________
39
fairness and honesty. Therefore, petitioners may not assail it on the mere ground that Supra, note 17.
40 Baylon v. Office of the Ombudsman, G.R. No. 142738, December 14, 2001, 372
it would allegedly put the accused at a disadvantage. Furthermore, a new counsel
cannot justify such withdrawal by the simple expedient of passing the blame on the SCRA 437.
previous counsel, who had supposedly not sufficiently discharged his duty to the client. 430
If we allow parties to renege on stipulations they validly entered into during the © Copyright 2019 Central Book Supply, Inc. All rights reserved.
course of pretrial proceedings, there would be no end to litigations. 34 Lawyers can
wiggle in and out of agreements the moment they are disadvantaged. Lawyers should
remember, however, that they are not merely representatives of the parties but, first
and foremost, officers of the court. As such, one of their duties—assisting in the speedy
and efficient administration of justice35—is more significant than that of acquitting their
client,36 rightly or wrongly.
We stress that candor in all dealings is the very essence of membership in the legal
profession. Lawyers are obliged to observe rules of procedure in good faith, not to
misuse them to defeat the ends of justice.37 They should realize that the earlier they
dispose of their cases, especially at the pretrial stage, the better for them. In doing so,
they can now concentrate and work more efficiently on their other cases. 38
_______________
33 Maryland Casualty Co. v. Rickenbaker, 146 F. 2d 751, December 15, 1944.
34 Gacutana-Fraile v. Domingo, 348 SCRA 414, December 15, 2000.
35 Muñoz v. People, 53 SCRA 190, September 28, 1973.

Page 5 of 5