Case Digest (G.R. No. 121039-45)
Facts:
The People of the Philippines v. Mayor Antonio L. Sanchez, et al., G.R. Nos. 121039-45, October 18, 2001, Special First Division, Melo, J., writing. The prosecution (the People) charged seven accused—Mayor Antonio L. Sanchez, George Medialdea, Zoilo Ama, Baldwin Brion, Luis Corcolon, Rogelio Corcolon, and Pepito Kawit—with seven counts of rape with homicide arising from the deaths of Eileen Sarmenta and Allan Gomez. Branch 70 of the Pasig City Regional Trial Court convicted all accused beyond reasonable doubt and imposed reclusion perpetua for each count, and awarded substantial civil and moral damages to the victims’ heirs.The accused appealed to the Supreme Court. In a January 25, 1999 decision penned by Justice Antonio M. Martinez, the Court affirmed the trial court’s conviction and sentence in toto but ordered each accused to pay an additional indemnity of P350,000.00 to each victim’s heirs (on the ground that each accused was found guilty of seven counts and each count carried P50,000.00 civil indemnity). Motions for reconsideration were filed by several accused-appellants (notably Mayor Sanchez, Zoilo Ama, Baldwin Brion and Pepito Kawit). The Office of the Solicitor General filed its Comment on December 6, 1999. Justice Martinez had retired, and by administrative raffle the pending motions were assigned on September 18, 2001 to Justice Melo for resolution.
In their motions the accused primarily argued (a) deprivation of an impartial trial by pervasive publicity (Sanchez), (b) lack of credibility or sufficient impeachment of the prosecution’s principal witnesses Aurelio Centeno and Vicencio Malabanan, (c) the alibi testimony of Sanchez’s 13‑year‑old daughter Ave Marie Sanchez placing him elsewhere on the night of the crime, and (d) that the awards of damages (actual, moral, funeral, loss of earning capacity, attorney’s fees) were excessive, unsupported, or resulted in double recovery. The Court reexamined the testimony (in...(Pro-only)
Issues:
- Were the accused denied the right to an impartial trial by prejudicial publicity?
- Were the convictions properly supported despite alleged impeachment and inconsistencies in the testimony of prosecution witnesses?
- Does Mayor Sanchez’s daughter’s testimony establishing an alibi warrant overturning his conviction?
- Are the awards of civil indemnity, funeral expenses, loss of earning capacity, moral damages, and litigation cos...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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