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Case Title: People v.

Yambot, GR 120350, October 13, 2000 of Sapang Jaen, Nueva Ecija and police officer Joe Villena of
Topic: Compulsory Process Gapan Police Station, Gapan, Nueva Ecija. Said subpoena,
however, was not served on Marie Maniego, who was
Facts: Freddie Yambot and Others were charged guilty beyond unknown at the given address, while in the case of Joe Villena,
reasonable doubt of the crime of kidnapping for ransom for he received the subpoena only on December 9, 1994.
wilfully, unlawfully and feloniously kidnap Francisco J. At the hearing on April 19, 1995, the trial court, on motion of
Bernabe for the purpose of extorting ransom, as in fact demand Atty. Prado, reset the presentation of evidence for appellants
therefor in the amount of P20,000,000. The appellants however Yambot and Versoza to May 15, 22, and 26, 1995; and issued
argued that they were not afforded their constitutional right of the corresponding subpoena for witnesses Marie Maniego and
due process and to adduce evidence on their behalf. Joe Villena, even as it reiterated its warning to declare a waiver
of appellants’ right to adduce evidence.

Issue: Whether or not the trial court gravely erred in not


affording accused-appellants Freddie yambot and francis
versoza of their statutory and constitutional rights, hence, they
should be acquitted.

Held:

Yes. Compulsory Process to Compel Production of Witnesses;


Enshrined in the constitution is the paramount right of the
accused to have a compulsory process to secure the attendance
of witnesses and the production of evidence in his behalf.—But
as regards appellants Freddie Yambot and Francis Versoza, it
appears that they were denied due process of law. Enshrined in
the constitution is the paramount right of the accused to “x x x
have a compulsory process to secure the attendance of
witnesses and the production of evidence in his behalf. 

In the case under consideration, appellants Yambot and


Versoza were scheduled to present evidence on December 12,
14, 16, 19, 21 and 23, 1994. Thus, on December 7, 1994,
subpoena was issued to appellants’ witnesses Marie Maniego

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