Case Summary (G.R. No. 217721)
Applicable Law and Procedural Posture
The proceedings center on the application of the 1987 Philippine Constitution, the Rules of Court (Rule 45 on petitions for review on certiorari), and the 2019 Amendments to the 1989 Revised Rules on Evidence. The petitioner’s conviction for homicide was affirmed by the CA, which dismissed his appeal and denied reconsideration, prompting the present petition to the Supreme Court contesting the sufficiency of evidence and the application of hearsay exceptions.
Facts and Prosecution Evidence
The prosecution presented witnesses Ricardo de Guzman, Ryan Cruz, and Alfredo Nerida, Sr. (the victim’s father), who testified that the victim identified the petitioner as his assailant after sustaining injuries during an altercation. De Guzman and Cruz recounted the victim’s bleeding injuries and his statements implicating the petitioner, which the victim made during a drinking session several hours after the injury. Nerida, Sr. confirmed that the victim’s injuries led to death and identified the petitioner as a relative and neighbor.
Defense Evidence and Medical Reports
The petitioner denied any altercation or infliction of injuries. Dr. Bernardo Parado, Municipal Health Officer, conducted the autopsy and testified that the victim’s lacerated wound was superficial. He also presented an autopsy opinion attributing death to blunt force injury to the occipital area, complicated by hypovolemic shock and intracranial hemorrhage. Contrastingly, the victim’s death certificate, prepared by Dr. Mark Anthony Cuevas and admitted as a common exhibit, listed the immediate cause of death as respiratory failure due to sepsis with underlying acute pancreatitis and pneumonia.
RTC Decision and Rationale
The Regional Trial Court found the petitioner guilty beyond reasonable doubt of homicide, sentencing him to an indeterminate penalty and ordering damages to the heirs of the victim. It heavily relied on the victim’s identification made to the prosecution witnesses and rejected the defense’s denial due to lack of countervailing evidence and absence of ill motive on the part of the witnesses.
Court of Appeals’ Affirmation
The CA affirmed the RTC decision, ruling that the victim’s declarations were not hearsay because they were not offered to prove the truth of the matters stated but rather to prove that the declarations were made (res gestae doctrine). It emphasized the spontaneity and close connection of the declarations to the incident and considered the prosecution witnesses’ testimony credible and sufficient to prove guilt beyond reasonable doubt.
Issues on Appeal to the Supreme Court
The petitioner challenged: (1) the sufficiency of evidence to prove guilt beyond reasonable doubt, (2) the admissibility of the victim’s declarations as exceptions to hearsay, specifically arguing they did not qualify as dying declarations or res gestae given the time lapse and circumstances of the statements, and (3) the conflicting medical evidence on cause of death.
Supreme Court’s Review of Evidence and Legal Principles
The Court underscored the constitutional presumption of innocence and the prosecution’s burden to prove guilt beyond reasonable doubt on its own evidence. It applied the equipoise rule, holding that when evidence equally supports guilt and innocence, the accused must be acquitted. Regarding medical evidence, the Court found the cause of death uncertain due to the contradiction between the death certificate indicating death from natural causes and the autopsy attributing death to injuries, creating reasonable doubt.
Hearsay Rule and Exceptions Analysis
The Court explained the hearsay rule prohibits testimony not based on personal knowledge, with recognized exceptions of dying declarations and res gestae statements. It enumerated the four requisites for a dying declaration, emphasizing the necessity of the declarant’s consciousness of impending death, which the Court found lacking in this case. The victim’s casual demeanor, delay in making statements, and continued drinking demonstrated absence of such consciousness.
Res Gestae Exception Examination
The elements for res gestae were recited: spontaneity, immediacy, and intimat
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Nature of the Case and Procedural History
- This case involves a petition for review on certiorari under Rule 45 of the Rules of Court, seeking to annul and set aside the May 29, 2014 Decision of the Court of Appeals (CA) and its March 20, 2015 Resolution, which denied reconsideration.
- The CA Decision affirmed the Regional Trial Court (RTC) of Bauang, La Union Branch 33’s April 24, 2012 Decision finding petitioner Benjie Lagao y Garcia guilty beyond reasonable doubt of homicide.
- The petitioner was charged through an Information dated April 30, 2008, for the homicide of Anthony Sumad-ong Nerida on or about February 20, 2008, in Bauang, La Union.
- Petitioner pleaded not guilty at arraignment and proceeded to trial, which culminated in his conviction.
Facts and Evidence Adduced at Trial
- Prosecution witnesses included Ricardo de Guzman, Ryan Cruz, and Alfredo Nerida, Sr., father of the victim.
- De Guzman observed the victim’s bleeding nose, and later the victim disclosed an altercation with the petitioner where he was hit on the nose and head.
- Both De Guzman and Cruz testified to the victim’s open head wound and his identification of the petitioner as the assailant.
- Nerida, Sr. corroborated that the victim informed him the petitioner caused the injuries leading to the victim’s death two days later, on February 22, 2008.
- The defense presented the petitioner denying the assault, and Dr. Bernardo Parado, who conducted the autopsy.
- Dr. Parado stated the victim’s lacerated wound was superficial, but his autopsy report attributed death to cardio-respiratory arrest due to intracranial hemorrhage from blunt force trauma on the occipital area.
- The death certificate, prepared by Dr. Mark Anthony M. Cuevas, indicated respiratory failure secondary to sepsis and complications such as pancreatitis and pneumonia as causes of death.
- The death certificate was admitted as a common exhibit.
Trial Court Decision and Rationale
- The RTC found the petitioner guilty beyond reasonable doubt of homicide, sentencing him to an indeterminate penalty of 8 years and 1 day to 12 years and 1 day of imprisonment.
- The RTC awarded actual damages, moral damages, death indemnity, and costs to the heirs of the victim.
- The RTC heavily relied on the declarations made by the victim to De Guzman and Cruz identifying the petitioner as the assailant.
- The trial court gave full faith and credit to these witnesses’ testimony, as there was no showing of ill motive.
Court of Appeals Decision and Reasoning
- The CA affirmed the RTC judgment, dismissing the petitioner’s appeal for lack of merit.
- It accepted the testimonies of the prosecution witnesses, ruling such were not hearsay but admissible as the fact of the victim’s utterance, not the truth of the matters stated.
- The victim’s declarations and the prosecution witnesses’ testimonie