Case Digest (G.R. No. 72709)
Facts:
This is People of the Philippines v. Alberto Padilla, G.R. No. 72709, promulgated August 31, 1989, the Supreme Court First Division, Medialdea, J., writing for the Court. The accused-appellant is Alberto Padilla; the prosecution is the People of the Philippines. The case arose from Criminal Case No. 2375 before the Regional Trial Court, Branch XXVII, Catbalogan, Samar (presided over by Judge Sinforiano A. Monsanto), where Padilla was charged with robbery with homicide under Article 294 (par. 1) of the Revised Penal Code.On the night of May 16, 1983, members of a fishing group slept aboard a motorboat beached at So. Badiang, Brgy. Bachao, Daram, Samar. At about 11:00 p.m. two men allegedly boarded the motorboat, robbed owner Rogelio Gososo of a wristwatch (P800) and cash (P2,200), and, in a separate encounter, stabbed sixteen‑year‑old crew member Esteban Labian, who later died from a heart‑perforating stab wound. Gososo identified Padilla among the four assailants; another witness, Paulino Quintas, was not called by the prosecution. Policeman Glicerio Gulane and members of the CHDF later found Padilla asleep at about 2:00 a.m. at the barangay tennis court, with a bloodstained bolo in his right hand and blood on the right side of his clothes; the bolo was removed by a CHDF member and Padilla was brought to custody.
At trial Padilla pleaded not guilty, asserted an alibi (he had been drinking tuba, then fell asleep at the tennis court while watching a motorboat), denied ownership of the bolo, and claimed he was in shock and was struck while in custody. Defense witnesses (Rodrigo Labian, father of the victim; and Barangay Captain Pepito Sevilla) implicated another suspect, Toto Mendido, but the trial court ruled those statements inadmissible as hearsay and not res gestae. The autopsy established the fatal stab wound.
On September 25, 1985 the trial court convicted Padilla as principal by direct participation of robbery with homicide and sentenced him to reclusion perpetua, ordered indemnities (P12,000 to the heirs of Labian; P3,000 to Gososo), costs, and confiscation of the bolo. Padilla appealed to the Supreme Cour...(Pro-only)
Issues:
- Did the trial court err in excluding the testimonies of Rodrigo Labian and Pepito Sevilla as inadmissible hearsay and not res gestae?
- Was the eyewitness identification by Rogelio Gososo sufficiently positive and reliable to support conviction?
- Did the prosecution prove Padilla’s guilt beyond reasonable doubt in view of the alibi, the circumstances of discovery (bloodstained bolo and clothing)...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)