Right to formally offer evidence WAIVABLE by inexcusable laxity
The trial court was correct in holding that petitioner waived the right to formally offer his evidence. A considerable lapse of time, about three (3) months, had already passed before petitioners counsel made effort to formally offer his evidence. For the trial court to grant petitioners motion to admit her exhibits would be to condone an inexcusable laxity if not non-compliance with a court order which, in effect, would encourage needless delays and derail the speedy administration of justice. [G.R. No. 116018. November 13, 1996]