Title
People vs. Dominguez y Santos
Case
G.R. No. 229420
Decision Date
Feb 19, 2018
A deceased state witness's testimony in a carjacking-homicide case was ruled admissible by the Supreme Court, affirming its validity despite his death and incomplete cross-examination.
A

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)

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