G.R. No. L-38790 - People vs. Relucio

The case arises from the conviction of Rosendo Velasco for the crime of murder committed in connection with the killing of Gonzalo Talastas, which occurred on June 23, 1971 in Cabanatuan City.
Velasco was charged along with several co-accused, including Federico Relucio (alias “Pedring”), Edri Pineda, Dante Ariola, Miguel Espejo Padrones (alias “Egi”), Peter Doe, and Richard Doe.
The information charged that the accused, acting in concert and using treachery, attacked and fatally shot Talastas during and after a trip to the Capital Theater.

The trial commenced on November 16, 1972 and concluded on November 5, 1973 following twenty-four sessions.
The court convincted Velasco and Relucio, sentencing them to reclusion perpetua and ordering indemnification to the heirs of the victim.
Federico Relucio voluntarily filed a motion for new trial and subsequently withdrew his appeal after breaking out of jail, thus leaving Velasco as the primary appellant in the appeal.

Evidence was primarily based on testimony from two key prosecution witnesses: Patrolman Crispin Angeles and Miguel Padrones.
Angeles testified about the events at the Capital Theater, including his vague account of persons seen chasing a wounded Talastas.
His testimony described meeting Talastas at the theater, witnessing unidentified persons chasing the victim, and provided an inconclusive description of who fired the fatal shots.
Angeles’ testimony was marked by inconsistencies especially when compared with his earlier sworn statement (Exhibit 17) given to Detective Fernandez in January 1972.

In open court, Angeles mentioned that he was positioned near the Avenue Theater when he heard gunshots and saw Talastas wounded, while in his earlier statement he provided a detailed account including the sequence of events inside and outside the theater.
The earlier statement (Exhibit 17) contained details of how a series of events unfolded inside the theater and subsequent chase that differed significantly from his live testimony.

Padrones, a co-accused later discharged as a state witness, testified that he was with Relucio and others in a residence before going to the Capital Theater based on information that Talastas was to be killed.
He recounted that he, together with others (including Velasco), proceeded to the theater and later followed a wounded Talastas by boarding a jeep.
His testimony, however, exhibited inconsistencies in recollections regarding the number of affidavits he executed, the dates, and the identity of the person who actually fired the fatal shots.
The witness’s statement on October 5, 1972 (and subsequent affidavits allegedly sworn before Judge Vicencio and Fiscal Del Rosario) directly implicated himself as the shooter rather than Velasco.

Exhibit 17 from Angeles’ prior sworn statement, which was submitted for impeachment purposes, contradicted his in-court assertion implicating Velasco.
A series of affidavits allegedly executed by Padrones (with dates October 5, October 19/20, and December 14, 1972) were introduced to refute the prosecution’s theory and cast doubt on the identification of the actual shooter.
Testimony from Judge Alfin Vicencio (formerly City Judge of Cabanatuan) corroborated that Padrones had indeed sworn to an affidavit on October 5, 1972, thereby challenging the trial court’s findings regarding the origin and content of Padrones’ statement.

The prosecution’s choice to rely on the testimonies of Angeles and Padrones was influenced by their presentation of contradictory and inconsistent evidentiary accounts.
The trial court and the district state prosecutor were noted to have engaged in ambiguous acts, including suppressing or failing to properly present vital affidavit evidence.
The manner in which the state prosecutor and trial judge handled discrepancies (e.g., the failure to object to improper impeachment techniques) played a significant role in the final appellate determination.

Whether the discrepancies between Angeles’ in-court testimony and his prior written statement (Exhibit 17) could be reconciled or should lead to the impeachment of his account.
Whether Miguel Padrones’ shifting accounts regarding the affidavits (including the date and place of execution before Judge Vicencio or Fiscal Del Rosario) undermined the prosecution’s evidence against Velasco.

Whether the testimonies of the prosecution witnesses are sufficient, consistent, and corroborated by other evidence to prove beyond reasonable doubt that Velasco participated in the killing of Gonzalo Talastas.
Whether the discrepancies and omissions in the presentation of affidavit evidence (notably, the alleged affidavit of October 5, 1972) could be viewed as evidence of prosecutorial misconduct or failure to secure critical evidence.

Whether the prosecution met the requirement for laying a proper predicate before introducing evidence of contradictory statements for witness impeachment.
Whether the defense’s waiver of the objection to the failure to lay such predicate affected the admissibility of the contradictory evidence.

Whether the failure to properly notify the defense regarding motions (such as the discharge of Padrones as a state witness) and the handling of evidence constitutes reversible error.
Whether such procedural lapses should result in a new trial or reversal of the conviction.