G.R. No. L-4497 - People vs. Isidro Peralta

The accused, Isidro Peralta, was initially charged with treason on two counts before the People’s Court.
Following the abolition of the People’s Court, the case was transferred to the Court of First Instance of Ilocos Norte, where the crime was alleged to have been committed.
The original information was amended twice, resulting in Eleven (11) counts of treason, without conducting the requisite preliminary investigation for the additional counts.
Counsel for the accused objected to the inclusion of these extra counts, but the court overruled the objections.

On the morning of August 25, 1942, at approximately 8:00 o’clock, while Lino Ratuita and Segundo Rubio were bathing in a river east of Pasukin, Ilocos Norte, Isidro Peralta, accompanied by five policemen, arrived at the scene.
Lino Ratuita and Segundo Rubio were arrested on the spot:

Ratuita was taken to the presidencia and later transferred to Laoag, where he was jailed.
Rubio, with his hands tied, was taken in a different direction and subsequently disappeared without further explanation.

On a certain day in August 1942, Balatico, a resident of Pasukin, was arrested by Peralta on the suspicion of having killed a Japanese.
Balatico was thrown into jail, deprived of food, and was forbidden from urinating, reflecting further mistreatment.

Lino Ratuita testified about his arrest and the subsequent maltreatment, identifying at least two policemen (Cariaga and Tagabilla) and noting that Policeman Prospero Ratuita assisted in his mistreatment.
Pedro Balatico’s testimony corroborated the occurrence of maltreatment during his arrest, despite his lapse in recalling certain chronological details.
Additional support came from witnesses Urbano Guerrero and Monico Caldito, whose testimonies, though challenged by the defense, supported the events described by the primary witnesses.

The alleged insufficiency of identification details from Ratuita on cross-examination.
The credibility of Balatico, who could not precisely state the year of his arrest or the details regarding Rubio’s condition.
The hearsay nature of part of Monico Caldito’s testimony, which was remedied by emphasizing his personal knowledge on other matters.

The defense’s case rested primarily on negative testimony, denying the positive allegations made by the prosecution witnesses.
Counsel asserted that the amendment of charges without proper preliminary investigations (for the additional counts) and certain testimonial inconsistencies should affect the reliability of the evidence against the accused.
The court referenced a prior resolution (G.R. No. L-3880) that had already dismissed issues concerning the lack of preliminary investigation for similar additional counts involving the same accused.

Whether the inclusion of additional counts (amended to Eleven counts) without the benefit of preliminary investigation was procedurally permissible.
The relevance and impact of the previous ruling (G.R. No. L-3880) in dismissing these procedural objections.

Whether the direct, positive testimonies of Lino Ratuita, Pedro Balatico, and other prosecution witnesses sufficiently established the commission of the offenses, despite minor inconsistencies.
To what extent the defense’s negative testimony and denial could counterbalance the clear and affirmative evidence presented by the prosecution.
Whether the alleged lapses in identification details and memory (such as Balatico’s uncertain recollection of the year) undermined the overall credibility of the prosecution witnesses.

Determining if the positive and corroborative accounts provided by the prosecution, including the supporting evidence of multiple witnesses, were enough to uphold the conviction on counts 6 and 7.
Evaluating whether the negative testimony and selective denials by the defense were inadequate in disproving the established events and identifications during the trial.