Santos vs. People (G.R. No. 147615; January 20, 2003)

VIRGILIO SANTOS, petitioner, vs. THE PEOPLE OF THE PHILIPPINES, respondent. Written by Justice Puno. (G.R. No. 147615; January 20, 2003; 395 SCRA 507)

In the case of People vs. Crispin, the Supreme Court held that the record of the preliminary investigation does not form part of the regional trial court records unless introduced as evidence during the trial. Absent such introduction, the records of preliminary investigation cannot be treated as evidence in court; neither may the trial court be compelled to take judicial notice of the same. A careful review of the records of this case, however, will show that the accused presented, and formally offered as evidence, the records of the preliminary investigation. Nonetheless, we remain unconvinced that these records will exculpate the accused. The dismissal of the case by the investigating municipal trial judge and by the provincial prosecutor was based on the report in the barangay blotter which we earlier held as highly unreliable and undeserving of any probative value. For good reasons, the dismissal of the case was reversed by the Secretary of Justice.