Case Summary (G.R. No. 150234)
Incident Details
On the night of the incident, Elpedio Presto, along with Anastacio and Domingo Lastrella, reported witnessing a confrontation between Florante Padrones and another individual. They alleged that Padrones threw a grenade after pulling its pin during an altercation. These eyewitness accounts were pivotal in the initial investigation but were later recanted by the witnesses due to claims of intoxication and misunderstanding at the time of their statements.
Recantation of Witness Statements
Over two months following the incident, the witnesses executed affidavits retracting their earlier statements. The Lastrellas claimed they were drunk at the time of the incident and uncertain about Padrones's involvement, indicating that their earlier claims were based on hearsay rather than direct observation. Similarly, Presto conveyed that he did not fully understand his original statement and suggested he might have mistakenly identified Padrones.
Charges Filed
By September 4, 1992, multiple charges were filed against Padrones, which included homicide, illegal possession of explosives, and violation of a Commission on Elections (COMELEC) resolution due to the nature of the incident occurring during an election period. His arraignment resulted in a plea of not guilty.
Trial Proceedings
During the trial, witness Nathan Hermosura testified for the prosecution, describing Padrones's involvement in the grenade incident. Despite being a new witness to the proceedings, the defense did not object to his testimony. His account contributed to the prosecution's narrative of events but came under scrutiny for inconsistencies, such as the proximity and timing of his observations during the explosion.
Defense Testimonies
Padrones testified in his defense, claiming that he was not the individual who threw the grenade but rather a victim of circumstance amidst a heated altercation with drunk individuals. He also claimed that the witnesses had pointed him out under duress or because of their confusion.
Trial Court Judgment
The trial court ultimately convicted Padrones on all counts, rendering a consolidated sentence that included a prison term for homicide and additional penalties for the other offenses. The court based its judgment on the testimonies presented, particularly accepting Hermosura’s account as credible despite the lack of corroborating evidence from other witnesses.
Appellate Court Review
On appeal, the Court of Appeals upheld the trial court’s ruling but modified the characterization of the homicide charge to murder. The appellate court focused on the credible testimony provided by Hermosura, dismissing the defense's claims and emphasizing the prosecution's evidence as sufficient to uphold the conviction.
Credibility of Witnes
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Case Overview
- The case involves the appeal of Florante Padrones against the conviction by the Regional Trial Court (RTC) of Puerto Princesa for three offenses stemming from a grenade explosion on April 9, 1992.
- The explosion resulted in the death of Elias Laurente and injuries to two children and an elderly woman.
- The Court of Appeals affirmed the RTC's decision with modifications, leading to the appeal to the Supreme Court.
Incident Description
- On the evening of April 9, 1992, at approximately 10:00 PM, a grenade exploded near the Northern Operators and Drivers Association (NODA) terminal in Puerto Princesa City, Palawan.
- The blast killed Elias Laurente, who was in his nearby home, and slightly injured two children and an elderly lady.
Testimonies and Statements
- Witness Accounts:
- Elpedio Presto testified that he witnessed an altercation involving Padrones and another individual. He claimed Padrones pulled the pin from a grenade and threw it.
- The Lastrellas also provided joint sworn statements indicating that Padrones was in possession of a grenade and threw it toward a nearby carinderia (small eatery).
- Recantation of Statements:
- Both Presto and the Lastrellas recanted their initial statements about Padrones’ involvement in a joint statement, citing intoxication and lack of clarity during the incident.
- The Lastrellas expressed uncertainty about identifying Padrones as the grenade thrower due to the darkness at the scene.
Criminal Charges Filed
- On September 4, 1992, charges were filed against Padrones for:
- Criminal Case No. 10104: Hom