Case Digest (G.R. No. L-68620)
Facts:
The People of the Philippines v. Freddie Tulagan alias "Eding", Valentin de Guzman alias "Satsoy", alias "Vicente", Ramon Mendoza, and Romeo "Romie" Mendoza, G.R. No. 68620, July 22, 1986, the Supreme Court En Banc, Narvasa, J., writing for the Court.The criminal episode began on the night of May 19, 1979, when 19‑year‑old Marlon Catungal sustained a single fatal stab wound to the chest and died from hemorrhage and shock, as shown by the autopsy (Exh. F). The wound penetrated the left lung and the ascending aorta. The deceased was pursued from a barrio fiesta dance at the public hall of Barangay Don Pedro, Malasiqui, Pangasinan, and his body was found later near the provincial road after having apparently been carried from a nearby azotea.
Prosecution witnesses included Bonifacio Ulanday, who gave a sworn statement and later testified that he followed at a distance some four persons—identified as Freddie (Eding) Tulagan, Valentin "Satsoy" de Guzman, Ramón Mendoza, and Romeo "Romie" Mendoza—chasing Catungal; Ulanday, however, admitted he did not see the stabbing itself. Natalia Macaraeg testified that on return to her store the three (or more) men told her they had run after and killed the neighbor (the victim), and that she observed blood on their persons.
On the basis of these and other statements, an information (Criminal Case No. CCC‑III‑0432) charged the four named accused with murder, alleging conspiracy, evident premeditation and abuse of superior strength, and asserting that Valentin de Guzman delivered the fatal stab while the others held the victim. Only Romeo "Romie" Mendoza was arrested and arraigned; he pleaded not guilty.
Following trial, the Circuit Criminal Court at Dagupan convicted Romeo Mendoza of murder and sentenced him to death by judgment promulgated August 9, 1984; the court ordered the case archived as to the other accused pending their arrest. The trial court relied in part on Natalia Macaraeg’s account of a declaration by Valentin de Guzman as being part of the res ges...(Subscriber-Only)
Issues:
- Was the statement attributed to Valentin de Guzman admissible against Romeo "Romie" Mendoza as part of the res gestae or as an oral confession?
- Was the evidence sufficient to prove beyond reasonable doubt that Romeo "Romie" Mendoza was guilty of murder, including the alleged qualifying circumstance o...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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