Title
People vs. Delasa
Case
G.R. No. L-36094
Decision Date
Jul 16, 1982
Anastacio Delasa is convicted of robbery with homicide, despite presenting new evidence in the form of witness retractions, as the Supreme Court emphasizes the importance of the trial process and denies his motion for a new trial.
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Case Digest (G.R. No. L-36094)

Facts:

  • Parties Involved: Plaintiff-appellee: People of the Philippines, Defendant-appellant: Anastacio Delasa.
  • Decision Date: July 16, 1982.
  • Court: First Division of the Supreme Court of the Philippines.
  • Justice: Relova as the ponente.
  • Incident Date: September 26, 1972.
  • Location: Sitio Calbugos, Villaba, Leyte.
  • Incident Details:
    • Victim: Anselmo Pondoyo.
    • Activities: Anselmo, his wife Virona, and son Alberto were harvesting rice.
    • Anselmo’s Actions: Went to gather camongay leaves.
    • Alberto’s Actions: Went to get ripe bananas.
    • Virona’s Observation: Anselmo was conversing with Anastacio Delasa and his son-in-law, Apolonio.
    • Attack: Delasa stabbed Anselmo twice with a bolo as he crossed an improvised bridge.
    • Aftermath:
      • Anselmo tried to crawl but was further injured by Delasa, who slashed his pants and took P500.00.
      • Anselmo died from his injuries.
  • Trial Court Decision: Convicted Delasa of robbery with homicide.
    • Sentence: Reclusion perpetua.
    • Indemnity: Ordered to pay P12,500.00 to the victim's heirs.
  • Appeal: Delasa appealed and filed for a new trial based on newly discovered evidence, including retractions by principal witnesses and an alleged eyewitness statement.

Issue:

  • (Unlock)

Ruling:

  • Affirmation of Conviction: The Supreme Court affirmed the trial court's decision, upholding the conviction of Anastacio Delasa for robbery with homicide.
  • ...(Unlock)

Ratio:

  • Credibility of Witnesses: The Supreme Court stressed that trial court findings on witness credibility should not be disturbed on appeal unless significant facts were overlooked.
  • Positive Identification: Eyewitnesses Virona and Alberto Pondoyo positively identified Delasa, which outweighed his alibi defense.
  • Alibi Defense: The Court found Delasa’s alibi implausible since the location he claimed to be at was not far from the crime scene.
  • Retractions of Witnesses: The Court cautioned against retractions, noting they could lead to endless litigation.
  • New Eyewitness: The alleged new eyewitness, Inocencio Damayo, did not qualify as newly discovered evidence because there was no indication that he could not have been found and presented during the original trial.
  • Precedents: Th...continue reading

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