Case Digest (G.R. No. 100225-26)
Facts:
People of the Philippines v. Raul Santos y Narciso, G.R. Nos. 100225-26, May 11, 1993, Supreme Court Third Division, Feliciano, J., writing for the Court.On 26 October 1989, Raul N. Santos (accused-appellant) was charged by information with (1) murder with use of unlicensed firearms (Crim. Case No. 8517-MN) and (2) frustrated murder (Crim. Case No. 8518-MN) for an ambush that occurred on 26 May 1989 in Navotas, Metro Manila. Three other persons were initially charged with him; the informations were later amended to name Mario Morales as a co-accused in lieu of John Doe, while two other assailants remained unidentified.
At trial the prosecution presented eyewitness testimony: the surviving victim Alberto Bautista, who was wounded but escaped, and Traffic Aide Victorino Bohol, who witnessed the ambush. Both identified Santos as one of the gunmen; Bautista also identified Mario Morales. Medical and investigative evidence (autopsy showing 19 gunshot wounds, hospital records, police sworn statements) were introduced. Police investigator Cpl. Sabino Patood testified to an admission by Santos during investigation; an affidavit by Ronaldo Guerrero in an unrelated but factually similar case at the same corner was offered and admitted under Section 34, Rule 130 (similar acts) for limited purposes. Santos offered an alibi supported by two family witnesses who said he was in Batangas at the time.
The trial court convicted Santos of murder and frustrated murder, sentenced him to life imprisonment (death abolished) and a term for frustrated murder, and ordered civil indemnities and expenses. On appeal to the Supreme Court, Santos chal...(Subscriber-Only)
Issues:
- Was the identification of accused Raul Santos by the prosecution witnesses admissible and sufficiently reliable, and was the accused’s alibi properly rejected?
- Was the trial court’s admission of the sworn statement (affidavit) of Ronaldo Guerrero — a witness in another case — permissible under Section 34, Rule 130 of the Rules of Court (similar acts) and not barred as hearsay?
- Should the judgment of conviction be affirmed and, if so, are any modifications to...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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