Case Digest (G.R. No. 68331)
Facts:
People of the Philippines v. Jose Santillan, G.R. No. 68331, January 29, 1988, the Supreme Court Second Division, Paras, J., writing for the Court.The prosecution (the People of the Philippines) charged Jose Santillan (accused-appellant) and his son-in-law Alex Pagapos with the murder of Domingo Era. At the Regional Trial Court (RTC), Fourth Judicial Region, Branch XXXIII, Siniloan, Laguna, the RTC found Santillan guilty beyond reasonable doubt of murder and sentenced him to reclusion perpetua with accessory penalties, ordered indemnity to the heirs of P12,000.00, payment of P2,900.00 for burial expenses, and one-half of the costs. Co-accused Pagapos remained at large.
The crime occurred at about midnight on September 9, 1979. Two prosecution witnesses, Rodolfo Acelajado and Vicente Recipide, testified that they saw Santillan and Pagapos hacking the unarmed victim with bolos at a ricefield in Barangay Bagong Pook, Sta. Maria, Laguna. Acelajado stated he was about fifteen meters away, that he had known Santillan and Pagapos for five years, and that a woman shouting the name “Jose” also helped identify Santillan. The medico-legal description in the record listed fourteen wounds and concluded death from shock and profuse hemorrhage due to multiple stab and incised wounds.
Santillan appealed the RTC conviction, assigning errors that attacked (1) the credibility of Acelajado and Recipide, (2) the RTC’s finding that the defense failed to show ill-motivation on the part of those witnesses, (3) the admissibility/credibility of originally unlisted witnesses, (4) the rejection of his alibi, and (5) the sufficiency of evidence to convict. The case reached the Supreme Court by appeal from the RTC decision. The Supreme Court reviewed the rec...(Pro-only)
Issues:
- Were the testimonies of prosecution witnesses Vicente Recipide and Rodolfo Acelajado credible and sufficient to support Santillan’s conviction for murder?
- Did the prosecution’s failure to list those witnesses in the information affect their credibility or the validity of the conviction?
- Was Santillan’s defense of alibi properly rejected as insufficient?
- In view of the abolition of capital punishment, wha...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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