Case Digest (G.R. No. L-2619)
Facts:
The People of the Philippines v. Melchor Soleta, G.R. No. L-2619, April 29, 1950, the Supreme Court En Banc, Ozaeta, J., writing for the Court.
The case arose from an information filed by the fiscal on April 15, 1948, charging Melchor Soleta (defendant-appellant) with murder allegedly committed on April 19, 1943, at Sitio Walos, barrio Bagtingon, Buenavista, Marinduque. The information named several alleged co-conspirators (Ricardo Perez, Rafael Soberano, and the already-deceased Enrique Llagono) and alleged aggravating circumstances of premeditation, treachery, abuse of confidence and superior strength, but the trial court convicted Soleta for the killing of a single victim, Juanito Luci, and sentenced him to suffer reclusion perpetua and to indemnify the heirs of the deceased in the amount of P8,000. Judge Juan P. Enriquez of the Court of First Instance of Marinduque rendered the conviction.
Procedural antecedents included an earlier complaint in March 1947 against the accused that had been dismissed by the justice of the peace after preliminary investigation for lack of prima facie evidence. The fatal incident was described in the information as occurring in 1943; the information was filed in 1948. At trial the prosecution primarily relied upon the testimony of a single eyewitness, Luis Sadiwa, while the defense presented the accused's own testimony and the testimony of Donato Magararu to place responsibility for the prisoners’ delivery to the guerrilla camp on other named guerrillas (Sofronio Justiniano, Ricardo Perez, Paulino Labay).
At the trial the material facts in evidence were sharply disputed. Sadiwa testified that on April 19, 1943 he accompanied Soleta and others who had two hog-tied captives to the guerrilla camp, that Lt. Llagono delivered the captives to others who then killed them, and that Soleta stabbed Juanito Luci. On cross-examination Sadiwa’s testimony contained multiple inconsistencies and admissions (e.g., uncertainty about when he was first asked to be a witness, conflicting statements about when he knew the accused and the victim, and an admission that he did not report the killings contemporaneously because he was afraid). The accused denied participation in the killings, testified that he himself had been arrested by guerrillas earlier and later released, and that he was not a guerrilla nor a civilian guard; Magararu corroborated the defense narrative that other guerrillas, not Soleta, brought the captives to the camp. The Cour...(Subscriber-Only)
Issues:
- Was the conviction of Melchor Soleta supported by proof beyond reasonable doubt?
- Was the uncorroborated testimony of the sole eyewitness, Luis Sadiwa, sufficiently credible and reliable to sustain a m...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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