Facts:

The case involves Eduardo Rosales, Hon. Rodolfo G. Palattao, and the People of the Philippines as petitioners against the Court of Appeals, Nelson Exconde, and Ronilo Anonuevo as respondents. The events leading to this case began on August 22, 1985, when separate Informations were filed in the Regional Trial Court of Lucena City, charging Eduardo Rosales, Crisanto Bautista, and private respondents Nelson Exconde and Ronilo Anonuevo with the murder of Marcial Punzalan, a former mayor of San Antonio and Tiaong towns in Quezon Province, along with Demetrio Ramos. These cases were consolidated and assigned to Branch 53, presided over by Judge Rodolfo G. Palattao. During the trial, the prosecution presented Eduardo Rosales and Crisanto Bautista as witnesses, subsequently moving for their discharge to allow them to testify as state witnesses. Their testimonies implicated prominent local political figures in the murders, leading to the filing of additional charges against these indi...

Facts:

Background of the Case:

• On 22 August 1985, separate Informations were filed before the Regional Trial Court (RTC) of Lucena City, charging Eduardo Rosales, Crisanto Bautista, Nelson Exconde, and Ronilo Anonuevo with the murder of Marcial Punzalan (a former mayor) and Demetrio Ramos.
• The cases were docketed as Crim. Cases Nos. 85-499 and 85-607 and were consolidated under Branch 53, presided by Judge Rodolfo G. Palattao.

Trial Proceedings:

• During the trial, the prosecution presented Eduardo Rosales and Crisanto Bautista as witnesses before moving for their discharge as state witnesses.
• Their testimonies implicated prominent local political leaders, including ex-Mayor Ananiano Wagan and ex-Mayor Francisco Escueta, as well as two barangay captains, leading to the filing of a new Information (Crim. Case No. 86-330) against these individuals.

Discharge of Rosales:

• The trial court granted the discharge of Rosales but deferred action on Bautista’s discharge pending resolution of the case.
• Private respondents (Exconde and Anonuevo) sought reconsideration of Rosales’ discharge, but their motion was denied.

Court of Appeals Decision:

• The Court of Appeals nullified the order of Rosales’ discharge, finding no plausible reason for it since Rosales had already testified and admitted guilt.
• The appellate court also noted the existence of an eyewitness, rendering Rosales’ testimony unnecessary.

Subsequent Events:

• Rosales was later killed on 3 August 1987 while the case was pending.
• Despite his death, the petitioners sought clarification on the legal issues surrounding his discharge, as the motion to discharge Bautista remained unresolved.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Compliance with Section 9, Rule 119:

   • The Court ruled that the discharge of Rosales satisfied the requirements of Section 9, Rule 119, which allows the discharge of an accused to become a state witness if:
     • There is absolute necessity for their testimony.
     • No other direct evidence is available.
     • Their testimony can be substantially corroborated.
     • They do not appear to be the most guilty.
     • They have no prior conviction involving moral turpitude.
   • Rosales’ testimony was crucial in implicating the alleged masterminds, and no other direct evidence was available to establish their involvement.

2. Deviation from Customary Practice:

   • The Court acknowledged that the prosecution deviated from the usual practice of discharging an accused before their testimony. However, this deviation was justified due to the imminent risk to Rosales’ life and the need to protect him while ensuring his cooperation.

3. Future Testimony as State Witness:

   • The Court emphasized that Rosales was still expected to testify against the alleged masterminds in Crim. Case No. 86-330, which was filed after his initial testimony. Thus, his discharge was in line with the intent of Section 9, Rule 119, which contemplates future testimony.

4. Legal Consequences of Discharge:

   • Under Section 10, Rule 119, the discharge of an accused operates as an acquittal and bars future prosecution for the same offense unless the accused fails to testify against their co-accused. Since Rosales did not fail or refuse to testify, his discharge was valid and irreversible.

5. Eyewitness Testimony:

   • The Court rejected the Court of Appeals’ finding that an eyewitness rendered Rosales’ testimony unnecessary. The alleged eyewitness never testified in court due to fear, making Rosales’ testimony indispensable.

6. Discretion of the Trial Court:

   • The Court upheld the trial court’s discretion in granting the discharge, emphasizing that the trial court is in the best position to assess the necessity and propriety of discharging an accused as a state witness.

Conclusion:

The Supreme Court ruled that the discharge of Eduardo Rosales as a state witness was valid and complied with the requirements of the Rules of Criminal Procedure. The Court of Appeals’ decision was reversed, and the trial court’s order discharging Rosales was reinstated.