Title
Supreme Court
Jimenez, Jr. vs. People
Case
G.R. No. 209195
Decision Date
Sep 17, 2014
Consolidated petitions challenged Montero’s discharge as a state witness in a murder case; SC upheld discharge, citing necessity, corroboration, and lack of grave abuse of discretion by the trial court.

Case Summary (G.R. No. 209195)

Key Dates

• May–June 2009 – Montero’s sworn confessions identifying his co-conspirators and the burial site of the victim
• August 20, 2009 – Information for murder filed before RTC
• March 19, 2010 – RTC (Judge Almeyda) denies discharge of Montero as state witness
• July 30, 2010 – Judge Docena reverses and grants discharge motion
• December 29, 2010 & June 29, 2011 – Judge Docena denies motions for reconsideration and inhibition; issues omnibus order
• May 22, 2012 – Court of Appeals grants Jimenez’s certiorari petition; later issues amended decision
• September 17, 2014 – Supreme Court decision

Applicable Law

• 1987 Philippine Constitution
• 1989 Revised Rules of Criminal Procedure, Rule 119 § 17 (discharge of accused as state witness)
• Rule 45 (petition for certiorari) and Rule 65 (certiorari under Rule 65) of the Rules of Court
• Rule 137 § 1 (inhibition of judge)

Factual Background

Montero, a former employee of the Jimenezes’ company, executed two sworn statements confessing to the abduction and killing of Ruby Rose Barrameda and naming Jimenez, his brother Lope, Lennard Descalso, Robert Ponce, and Eric Fernandez as co-conspirators. Based on Montero’s directions, authorities recovered a cadaver encased in a drum near the indicated location. The People filed murder charges against all six. Montero then moved for discharge under the Witness Protection Program (R.A. 6981) and as a state witness pursuant to Rule 119 § 17; Jimenez opposed.

Proceedings in the Regional Trial Court

– March 19, 2010 (Judge Almeyda): Denied discharge, finding the prosecution failed to prove necessity, corroboration of Montero’s testimony, or that Montero was not the most guilty.
– July 30, 2010 (Judge Docena): Reversed, holding Montero’s extrajudicial confession was the sole direct evidence, corroborated by recovered physical evidence, and that he was not the most guilty among principals.
– December 29, 2010 & June 29, 2011: Judge Docena denied Jimenez’s motions for reconsideration and for inhibition, and granted a separate motion suspending proceedings as to another co-accused.

Court of Appeals Ruling

The CA initially granted Jimenez’s petition for certiorari (Rule 65), annulling Judge Docena’s orders. On reconsideration, it issued an amended decision upholding:

  1. The trial court’s compliance with Rule 119 § 17 in granting Montero’s discharge as state witness (necessity, lack of other direct evidence, substantial corroboration, relative guilt, and absence of prior moral-turpitude conviction).
  2. The factual determination that Montero was not the most guilty.
  3. The requirement to re-raffle the case to another RTC branch to avoid any appearance of bias, despite finding no mandatory ground for inhibition.

Issues before the Supreme Court

  1. Whether the CA erred in finding no grave abuse of discretion by Judge Docena in discharging Montero as a state witness.
  2. Whether the CA erred in ordering the re-raffle of the case on the theory of voluntary inhibition.

Supreme Court Ruling on Discharge of State Witness (G.R. No. 209195)

• Standard of Review – certiorari relief lies only for clear and patent grave abuse of discretion.
• Rule 119 § 17 Requirements – five mandatory conditions were uncontested except: necessity of testimony, prior hearing, corroboration, and relative guilt.
• Absolute Necessity – Montero alone possessed direct knowledge; no other conspirator would testify; jurisprudence (Chua v. CA; People v. Perez; Tan) upholds necessity regardless of number of accused.
• Substantial Corroboration – physical evidence (steel casing, drum, location, victim’s apparel and remains) confirmed material points of Montero’s statements; minor discrepancies are trial issues.
• Relative Guilt – “most guilty” means greatest participatory culpability, not severity of penalty. Montero’s acts (welding, operating boat, disposal) were less central than those who planned and ordered the killing. The trial court’s factual finding is binding absent grave abuse.
• Prior Hearing – Jimenez estopped from raising lack of hearing; he actively participated in pleadings and the absence of formal hearing did not prejudice substantive resolution (People v. Pring)



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