G.R. No. 150234 - People vs. Padrones

Case Digest (G.R. No. 150234)
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Facts:

Incident and Immediate Aftermath

On April 9, 1992, at around 10:00 o’clock in the evening, a grenade exploded near the Northern Operators and Drivers Association (NODA) terminal at Malvar Street, Puerto Princesa City, Palawan.
The explosion resulted in the death of Elias Laurente, who was at the second floor of his two-story house, and caused slight injuries to two children and an elderly lady in the vicinity.

Preliminary Testimonies by Witnesses

On April 10, 1992, Elpedio Presto, of Barangay Matahimik, Puerto Princesa City, gave a sworn statement before the police, alleging that:

He was watching television when his wife’s cousin fetched him to assist Ome Pareja at the NODA terminal.
Upon Ome’s emergence and a subsequent altercation, the accused-appellant, Florante “Anggay” Padrones, immediately pulled the pin of a grenade and threw it at his adversaries.

On the same day, Anastacio Lastrella and Domingo Lastrella also gave a joint sworn statement before the police, alleging that:

They saw two drunk individuals, identified with the names “Anggay Padrones” and “Romeo Pareja ‘alias Ome’”, carrying a grenade.
Appellant was observed holding the grenade and warning the opposing party not to come near him, followed by throwing the grenade toward a nearby carinderia.

Subsequently, all three witnesses (Presto and the Lastrellas) executed later affidavits (Pagbabawi ng Salaysay) on June 17, 1992, recanting or modifying aspects of their original statements:

They cited inebriation and confusion during the original incident and during the taking of the initial statement.
They expressed uncertainty as to whether it was indeed “Anggay Padrones” who threw the grenade, noting that poor visibility (“may kadiliman”) prevented them from being certain.

Filing of Charges and Details of the Informations

Approximately five months after the incident, on September 4, 1992, three Informations were filed against Florante Padrones before the RTC of Puerto Princesa City which were consolidated at Branch 51.
The charges were:

Criminal Case No. 10104 – Homicide: Alleging that on April 9, 1992, Padrones, together with accomplices, threw a grenade that fatally wounded Elias Laurente.
Criminal Case No. 10314 – Violation of COMELEC Resolution No. 2323: Alleging that Padrones possessed a hand grenade without the requisite permit or license.
Criminal Case No. 10315 – Violation of Presidential Decree No. 1866: Similarly alleging illegal possession of a hand grenade without the necessary permit.

Evidence Presented at Trial

Prosecution’s Evidence:

The prosecution relied on the initial testimonies of Presto and the Lastrellas (later recanted) as key evidence against the accused.
The prosecution introduced testimony of eyewitness Nathan Hermosura, a tricycle driver, who for the first time since the incident gave a detailed account of:

Observing the accused (identified as “Anggay Padrones”) arriving at the scene on a tricycle accompanied by a companion.

ii. Witnessing an altercation followed by the accused positioning himself in the middle of the road holding a hand grenade. iii. Noting that the accused pulled the grenade’s safety pin and threw it at about 2 to 3 meters away from himself, with the grenade exploding roughly ten seconds later.

Additional evidence included medical testimony from the doctor who treated Elias Laurente, a testimony by Elias’s brother Ruben Laurente regarding damages, and a statement by SPO1 Rolando Amorao of the PNP verifying that the accused was not properly licensed to possess explosives.

Defense’s Evidence:

The accused, Florante Padrones, admitted to being present at the NODA terminal on the night of the explosion but maintained that he had no memory or knowledge of throwing the grenade.
Padrones provided a narrative of being approached by three strangers who instigated an altercation, after which one of them threw an object that exploded, leading him to retreat.
Romeo Pareja, a witness called by the defense and father of two children injured in the incident, testified that although he observed an altercation near the NODA terminal, he did not see clearly who threw the grenade.

Trial Court and Appellate Proceedings

At Trial:

Branch 52 of the RTC of Puerto Princesa City rendered a consolidated judgment convicting Florante Padrones on all three charges.
The conviction for homicide resulted in a sentence ranging from eight years, one day to fourteen years, ten months of reclusion temporal, with additional orders for payment of actual, compensatory, and civil damages.
Convictions under the other two charges (violation of COMELEC Resolution and PD 1866) were similarly pronounced with corresponding penalties.

On Appeal:

The Court of Appeals, in a decision dated October 18, 2001, affirmed the trial court judgment with modifications.
The appellate court reclassified the homicide charge as murder under Article 248, paragraph 3, of the Revised Penal Code, noting an increased penalty in light of the evidence.
The appellate decision, however, disregarded the conviction under PD 1866 due to the enactment of Republic Act No. 8294.
The credibility of prosecution witness Hermosura’s testimony was heavily relied upon by the appellate court in condemning the accused.

Testimony Analysis and Credibility Issues

The testimony of Hermosura, despite being the main evidence against the accused, was fraught with inconsistencies:

His account on direct examination detailed contradictory information regarding the duration he observed the accused holding the grenade, the distance between the parties, and the proximity to the explosion.
His claims regarding the positioning of the victim, Elias Laurente, and his knowledge of the events (such as how he came to know that Laurente was upstairs) conflicted with common sense and other corroborative evidence.

Cross-examination further exposed:

Hermosura’s inability to clearly identify and name the injured children, despite asserting he personally assisted in taking them to the hospital.
Discrepancies in distances reported (e.g., being five meters away versus the children being only two or three meters from the explosion).
Inherent improbabilities in his observations during a night scene with limited lighting.

Conclusion of the Case

The Supreme Court, upon reviewing the entire record, found that:

The prosecution failed to prove beyond reasonable doubt the guilt of Florante Padrones.
Hermosura’s testimony, being inconsistent and lacking credibility, did not meet the inherent standard required for convicting a person in a criminal case.

Accordingly, the Court reversed and set aside the consolidated judgment of the Court of Appeals and acquitted the accused of all crimes charged.
A directive was issued for the immediate release of Florante Padrones unless he was detained for another lawful cause.

Issues:

Reliability and Credibility of Witness Testimonies

Whether the recantation of the initial eyewitness statements (by Presto and the Lastrellas) cast sufficient doubt on the prosecution’s case.
Whether the inconsistencies and improbabilities in Nathan Hermosura’s testimony were sufficient to undermine his evidence against the accused.

Sufficiency of the Prosecution’s Evidence

Whether the evidence adduced, particularly the eyewitness testimony, met the burden of proving guilt beyond reasonable doubt.
Whether the prosecution could establish a clear chain of causation linking the grenade explosion to the accused’s actions.

Consideration of the Defendant’s Version

Whether the defendant’s narrative of an unpremeditated encounter with strangers and subsequent retreat constituted a credible alternative explanation.
Whether the discrepancies between the defense and prosecution accounts could be reconciled in light of the evidence presented.

Ruling:

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Ratio:

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Doctrine:

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