G.R. No. L-62072 - People vs. Santos

The case involves the People of the Philippines versus several accused, all serving sentences in the New Bilibid Prison in Muntinlupa, Rizal.
The accused include Renato Santos, Romeo Gutierrez, Antonio Juaningo, Alfredo Gonzales, Joseph Lanuza, and Jose Perez.
The crime charged is the murder of fellow inmate Danilo Mangaliman, committed within the prison premises.

On January 16, 1977, at about 3:00 in the afternoon, an altercation occurred inside Dormitory 5-A of the National Bilibid Prison.
During the heated confrontation, Renato Santos stabbed Danilo Mangaliman, which resulted in a fatal stab wound in the abdomen.
The victim was rushed to the prison hospital but succumbed to profuse hemorrhage the following day, as confirmed by Dr. Ampil, the medico-legal officer of the NBI.

At arraignment, Renato Santos admitted guilt, whereas his co-accused pleaded not guilty.
The trial court’s decision was primarily based on the testimony contained in the sworn affidavit (Exhibit “C”) of prisoner Romeo Fernandez, who provided an account of the incident but never testified in court.
Additional testimonies were given by Prison Officers Vivencio Lahus and Francisco Cometa, Jr., Dr. Pedro Ampil, and prisoner Alberto Alvarez, none of which sufficiently linked the co-accused to the crime.
Beyond the criminal penalties, the accused were also ordered to indemnify the victim’s heirs and pay moral and exemplary damages.

The trial court found all accused guilty beyond reasonable doubt based solely on the hearsay evidence from Romeo Fernandez’s affidavit.
Renato Santos was sentenced to death based on his voluntary confession, while the co-accused were similarly sentenced to death based on the uncorroborated affidavit.
The reliance on such hearsay evidence without the opportunity for cross-examination was later challenged as a violation of the constitutional right to confront one’s accuser.

The appellate court (En Banc) scrutinized the evidentiary basis of the conviction, particularly the use of hearsay evidence.
The court acknowledged that the untested affidavit violated the accused-appellates’ right to face witnesses.
The conviction of the co-accused was set aside, and the death sentences against them were reversed, while the conviction of Renato Santos was affirmed but his sentence was reduced to reclusion perpetua.
The civil indemnity awarded to the victim’s heirs was increased from P12,000.00 to P30,000.00.

Whether the trial court’s reliance on the sworn affidavit of Romeo Fernandez, which was never subjected to direct cross-examination, violated the accused’s constitutional right to confront their witnesses.
Whether such hearsay evidence can serve as the exclusive basis for a conviction in a capital case.

Whether the evidence, apart from Renato Santos’ voluntary confession, was sufficient to prove the participation of the co-accused in the murder beyond reasonable doubt.
Whether extending criminal liability to co-accused based solely on an uncorroborated affidavit meets the evidentiary standards required in capital cases.

Whether the trial court properly evaluated the alibi defense put forward by the co-accused instead of dismissing it outright.
Whether the failure to objectively weigh the alibi defense contributed to an unjust conviction of the co-accused.