Case Summary (G.R. No. 92847)
Applicable Law
The pertinent laws in this case are drawn from the 1987 Philippine Constitution, particularly concerning the rules surrounding the discharge of a state witness and the evidence required for a conviction, as established in Section 9 of Rule 119 of the Rules of Court.
Facts of the Case
On May 28, 1983, two deceased individuals were found shot to death on a roadside, their deaths attributed to gunshot wounds. Following an investigation, suspicion fell on three soldiers from the 152nd PC Company, all of whom had used a jeep found later with visible damage and bloodstains. During interrogations, mutual accusations of guilt occurred among the suspects. Paraffin tests showed positive results for gunpowder residue on Estoesta but negative for the other two. Ballistics revealed that the shells found matched the firearms assigned to Quiming and Lamigo. Subsequently, all three were charged with double murder.
Discharge of State Witness
Despite the defense’s objection, Catalino Quiming was discharged as a state witness, which was later upheld by the trial court. The legal test for such a discharge requires that the prosecution demonstrate the necessity of the witness's testimony, availability of corroborating evidence, and the accused's lack of greatest culpability. In this case, it was determined that Quiming's testimony was crucial, especially since neither Estoesta nor Lamigo was willing to implicate him directly.
Credibility of Witnesses
The discharge procedures led to a conflict regarding the credibility of Quiming’s testimony, which Estoesta claimed was perjurious and contradictory. However, the court maintained that credibility alone does not justify a denial of discharge under the stipulated requirements. The trial court's discretion in evaluating the state's necessity for Quiming’s testimony was deemed appropriate.
Evidence and Testimony
From the evidence, Estoesta emerged as the sole perpetrator of the crime. His role was emphasized as the leader during the events preceding the murders. On the day of the incident, they had been drinking and acted on impulse when picking up the hitchhikers, leading to the shooting. Estoesta ordered the bodies disposed of, evidencing his direct involvement.
Evaluation of Testimonial Discrepancies
Estoesta attempted to undermine the credibility of both Quiming and Lamigo by pointing to alleged inconsistencies in their testimonies regarding who shot the victims. The court reiterated that variances in testimony do not inherently affect credibility and can often arise from the circumstance of initial statements being made under duress or without legal counsel. The court found that the discrepancies were minor and did not significantly impact the overall veracity of the accounts.
Court’s Findings on Guilt
The court affirmed Estoesta's conviction of double murder, emphasizing that while the killings showed treachery due to the victims' defenselessness, there was insuffi
...continue readingCase Syllabus (G.R. No. 92847)
Case Overview
- This case involves the conviction of Robin Estoesta for the double murder of Herminio Casimiro and Pedro Robina, with the issue revolving around the validity of the dismissal of a state witness and the credibility of his testimony.
- The trial court found Estoesta guilty, sentencing him to reclusion perpetua for each murder, while Lamigo was acquitted due to insufficient evidence.
Incident Background
- On May 28, 1983, the bodies of two men were discovered along a road in Barangay Carmay, Rosales, Pangasinan, showing signs of gunshot wounds.
- Autopsy confirmed the cause of death as shock from massive hemorrhage due to gunshot wounds. Sixteen empty shells were found near the victims’ bodies.
- The investigation led to three soldiers from the 152nd PC Company being suspected: Robin Estoesta, Herminigildo Lamigo, and Catalino Quiming, who had used a mini-cruiser jeep with bloodstains and a dented bumper.
Interrogations and Evidence
- During separate interrogations, Estoesta accused Lamigo of being the shooter, while Lamigo pointed to Estoesta, and Quiming also implicated Estoesta.
- Paraffin tests showed a positive result for Estoesta and negative for both Lamigo and Quiming.
- Ballistics tests linked the empty shells to the firearms assigned to Lamigo and Quiming.
Prosecution and Trial
- On September 23, 1980, all three