Title
People vs. Valdemoro
Case
G.R. No. L-51367
Decision Date
Jan 22, 1981
A man's murder conviction is upheld despite his co-accused's charge dismissal for lack of evidence, with the Supreme Court finding no denial of due process.
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Case Digest (G.R. No. L-51367)

Facts:

  • Philip Valdemoro was convicted of murder by the Circuit Criminal Court in Masbate on April 6, 1973.
  • He was sentenced to imprisonment from ten years and one day of prision mayor to twelve years and one day of reclusion temporal.
  • Valdemoro was ordered to indemnify the victim's heirs, Josefino Rejuso, in the amount of P15,000 and to pay court costs.
  • Co-accused Federico Vargas and Rolando Cos were acquitted.
  • The case was elevated to the Court of Appeals, which affirmed the conviction on July 30, 1979, but modified the penalty to reclusion perpetua.
  • The Information filed on July 26, 1972, charged Valdemoro and others with murder for shooting Josefino Rejuso.
  • The case was transferred to the Circuit Criminal Court due to a conflict of interest.
  • The defense presented a written confession from Ricardo Arcueno, who claimed responsibility for the murder, but the trial court dismissed the charges against him.
  • Prosecution witnesses Reynaldo Khiong and Nylon Espenilla testified that they saw Valdemoro shoot Rejuso without provocation.
  • The defense sought to discredit the prosecution's witnesses and argued against the dismissal of Arcueno's case.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the Court of Appeals' judgment, upholding Valdemoro's conviction for murder and sentencing him to reclusion perpetua, along with ac...(Unlock)

Ratio:

  • The Supreme Court found no error in dismissing the charges against Ricardo Arcueno due to insufficient evidence linking him to the crime.
  • The court emphasized that the prosecution has discretion to dismiss cases lacking competent evidence, which did not violate Valdemoro's right to due process.
  • Arcueno's confession was deemed not credible, as he was not identified by eyewitnesses and his account contained implausibilities.
  • The testimonies of...continue reading

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