Case Digest (G.R. No. 219681-82)
Facts:
On January 13, 2011, Venson Evangelista, a car salesman, was abducted in Cubao, Quezon City, and his charred remains were found the next day in Cabanatuan City, Nueva Ecija. In connection with this, Alfred Mendiola and Ferdinand Parulan voluntarily surrendered to the PNP and executed extrajudicial confessions implicating respondents Roger and Raymond Dominguez, Jayson Miranda, Rolando Taiban, and Joel Jacinto as the perpetrators of Carnapping with Homicide (Criminal Case No. Q-11-168431). On April 11, 2011, the Dominguez brothers and Miranda pleaded not guilty. On June 27, 2011, the prosecution moved to discharge Mendiola as an accused to become a state witness. After a hearing during which Mendiola testified and was cross-examined only on issues of qualification (the defense reserving fuller cross-examination for trial proper), the RTC granted his discharge on September 29, 2011, holding that his sworn statement and testimony would automatically form part of the evidence. On Ma...Case Digest (G.R. No. 219681-82)
Facts:
- Abduction and Death of Venson Evangelista
- January 13, 2011 – Venson Evangelista was abducted in Cubao, Quezon City; charred remains found January 14 in Cabanatuan City.
- Alfred Mendiola and Ferdinand Parulan surrendered to the PNP and executed extrajudicial confessions identifying Roger and Raymond Dominguez as masterminds.
- Criminal Proceedings in RTC Branch 215, Quezon City
- January 2011 – Information for Carnapping with Homicide (RA 6539, §14) filed against Mendiola and respondents (Dominguez brothers, Jayson Miranda, Rolando Taiban, Joel Jacinto).
- April 11, 2011 – Arraignment; Dominguez brothers and Miranda pleaded not guilty; Taiban and Jacinto remained at large.
- June–July 2011 – Prosecution moved to discharge Mendiola as state witness; he testified and was cross-examined limited to discharge issues.
- September 29, 2011 – RTC granted discharge; ordered Mendiola’s testimonies of June 27, July 8 and 11, 2011 and related evidence to form part of trial.
- May 6, 2012 – Mendiola died; parties submitted position papers on admissibility of his discharge testimony.
- January 10, 2014 – RTC ordered Mendiola’s June 27, 2011 testimony stricken off record, citing due process and confrontation rights.
- May 27, 2016 Decision and January 18, 2017 Resolution – Court of Appeals affirmed RTC’s order.
- February 2017 – Office of the Solicitor General filed a Rule 45 petition before the Supreme Court.
Issues:
- Admissibility of Discharge Testimony
- Whether Mendiola’s testimony during the discharge proceeding, now deceased, should be stricken from the records.
- Whether respondents’ constitutional right to confront and cross-examine was violated by non-presentation of Mendiola at trial proper.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)