Title
People vs. Meneses y Marin
Case
G.R. No. 111742
Decision Date
Mar 26, 1998
A seven-year-old’s identification of his uncle as his father’s killer was deemed unreliable due to poor lighting, suggestive police procedures, and inconsistent testimony, leading to acquittal.

Case Digest (G.R. No. 111742)
Expanded Legal Reasoning Model

Facts:

  • Parties and Nature of the Case
    • Roman Meneses y Marin (appellant) was charged with the murder of Cesar Victoria (victim) pursuant to an Information dated December 27, 1991.
    • The case arose from the stabbing death of Cesar Victoria in a rented makeshift room in Tondo, Manila at around 3:00 AM on December 15, 1991.
  • Circumstances of the Crime
    • Cesar Victoria, 33 years old, was found stabbed multiple times, sustaining fatal wounds inflicted with a fan knife (balisong).
    • The stabbing was allegedly witnessed by his seven-year-old son, Christopher Victoria, who resided with his father in the rented makeshift room, adjacent to a house owned by the Spouses Ardiete.
    • According to Christopher, he was awakened by the stabbing and saw his father being stabbed by the assailant, whom he later identified as appellant.
  • Prosecution Evidence
    • Christopher Victoria testified that he witnessed appellant stabbing his father.
    • SPO3 Jaime Mendoza, investigator, testified that Christopher initially could not name the attacker immediately after the crime but later identified appellant upon a confrontation at the police precinct.
    • SPO3 Eduardo Gonzales apprehended appellant on December 25, 1991, based on a tip from appellant’s wife, Angelina Victoria, who implicated Roman Meneses in the crime. A balisong was recovered from appellant at arrest.
    • Medico-Legal Officer Florante Baltazar conducted the autopsy and confirmed the cause of death as cardio-respiratory arrest due to hemorrhage from stab wounds; noted that the victim was likely standing or sitting when stabbed.
  • Defense Testimony
    • Appellant testified denying the charges, asserting an alibi that he was in San Isidro, Mexico, Pampanga from December 10 or 11, 1991.
    • He denied animosity or motive against the victim and claimed he was mauled during arrest, with no confession made.
    • Defense maintained that appellant’s wife’s accusations and Christopher’s identification were unreliable and possibly coached.
  • Trial Court Decision
    • On July 26, 1993, the trial court convicted appellant of murder and sentenced him to reclusion perpetua.
    • The court also ordered appellant to pay P50,000.00 damages to the heirs of the victim.

Issues:

  • Whether the trial court erred in disregarding the exculpatory evidence presented by the defense.
  • Whether the prosecution proved appellant’s guilt beyond reasonable doubt despite questionable eyewitness identification.
  • Whether the conviction of murder was proper or whether the crime should have been classified as homicide.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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