Case Digest (G.R. No. 98252)
Facts:
People of the Philippines v. Rene Januario y Roldan, Efren Canape y Bayot, Eliseo Sarita @ Toto, Eduardo Sarinos and Santiago Cid; G.R. No. 98252, February 07, 1997, Supreme Court Third Division, Panganiban, J., writing for the Court.The prosecution (the People of the Philippines) charged appellants Rene Januario and Efren Canape (with co-accused Santiago Cid, Eliseo Sarita @ Toto and Eduardo Sarinos @ Digo) with violation of Republic Act No. 6539 (the Anti-Carnapping Law) arising from the September 4, 1987 carnapping and killing of a jeepney driver and conductor. An Information was filed November 7, 1988; Januario and Canape pleaded not guilty at arraignment, Cid later pleaded not guilty, while Sarita and Sarinos remained at large.
At the trial before the Regional Trial Court of Cavite, Branch XVIII (Tagaytay City), the prosecution presented witnesses including NBI agents, eyewitnesses and two lawyers (Atty. Magno Toribio and Atty. Carlos Saunar). The NBI recovered the jeepney; investigation traced disposition of the vehicle through Cid to a buyer. The key evidence against Januario and Canape were their extrajudicial sworn statements executed at the NBI head office and testimony of Atty. Saunar that he assisted them during the taking of those statements.
The trial court admitted the prosecution’s evidence, denied the defense demurrer to evidence, allowed the prosecution to present Atty. Saunar as an additional/rebuttal witness after the prosecution rested, and on June 27, 1990 convicted Januario and Canape under Sec. 14 (last sentence) of RA 6539, imposing reclusion perpetua and awarding damages; Cid was acquitted. T...(Pro-only)
Issues:
- Did the trial court err in allowing Atty. Carlos Saunar to testify as an additional/rebuttal witness after the prosecution had rested and the defense had closed?
- Were the extrajudicial confessions and verbal admissions of appellants admissible in evidence when taken in the presence of Atty. Saunar, who was secured by the NBI and later employed by that agency?
- If the confessions are excluded, is there sufficient remaining evidence to sustain ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)