G.R. No. 167333 - Ladines vs. People

On or about June 12, 1993, during the Grand Alumni Homecoming dance of Bulabog Elementary School in Sorsogon, Sorsogon, the petitioner, Pedro Ladines, along with his alleged co-accused, Herman Licup, was present near the scene.
While prosecution witnesses and the victim, Erwin de Ramon, were watching the dance, Ladines and Licup passed by. Without warning, Ladines abruptly approached Erwin and stabbed him below the navel with a machete; Licup also attempted an attack but Erwin evaded the blow.
After the stabbing, Erwin struggled with Licup – at one point pulling the machete from his body and wielding it against Licup, resulting in both men falling down. Erwin was rushed to the hospital, where he later succumbed to his injuries.

Post-mortem examination by Dr. Myrna Listanco revealed two stab wounds on Erwin’s body: one on the chest and another on the abdomen.
The doctor opined that the injuries were likely inflicted with two distinct sharp instruments—possibly a sharpened screwdriver for the chest wound and a knife for the abdominal injury.

An information charging homicide against Ladines and Licup was filed in the Regional Trial Court (RTC) on August 12, 1993.
On February 10, 2003, the RTC found Pedro Ladines guilty beyond reasonable doubt of homicide under Article 249 of the Revised Penal Code, sentencing him to an indeterminate penalty of ten (10) years and one (1) day prision mayor as a minimum and seventeen (17) years and four (4) months reclusion temporal as a maximum, along with a civil indemnity of P50,000.00.
Herman Licup was acquitted by the RTC for insufficiency of evidence, and his bond was accordingly cancelled and discharged.

Ladines claimed an alibi, maintaining that at the time of the incident he was within the Bulabog Elementary School compound with his wife and minor child, and had left early due to disturbances.
He asserted that he learned of the stabbing incident only later from a local informant and that prosecution witnesses, Philip de Ramon and Mario Lasala, harbored ill-will against him because he had lodged a complaint against them for theft.
His defense witnesses, Angeles Jasareno and Arnulfo Palencia, corroborated his alibi, testifying that they were with him and his family inside the dance hall, thereby contesting his alleged involvement.

In his appeal, Ladines argued that the trial court erred by imposing the highest portion of the penalty period without specifying any aggravating circumstances.
He further contended that the res gestae statement of Licup—taken immediately after the incident—should be considered newly-discovered evidence that created a reasonable doubt regarding his guilt.
The State countered that the issues raised were improper for an appeal on certiorari under Rule 45, as only questions of law (and not fact or evidentiary credibility) may be raised at this level.

Whether the lower courts erred in imposing the maximum (upper limit) of the indeterminate penalty without stating specific aggravating circumstances, contrary to the mandatory guidelines provided under Article 64 of the Revised Penal Code.

Did the courts’ imposition of seventeen (17) years and four (4) months of reclusion temporal as the maximum sentence constitute an arbitrary and capricious determination?

Whether the res gestae statement of Herman Licup qualifies as newly-discovered evidence that could raise a reasonable doubt on the petitioner’s guilt.

Is the evidence in question applicable on appeal, particularly given the procedural limitations on introducing evidence at this stage?

Whether questions related to the probative value of evidence (fact issues) were improperly raised in an appeal that should strictly limit itself to questions of law under Section 1, Rule 45 of the Rules of Court.