Case Summary (G.R. No. L-30707)
Background of the Case
On January 4, 1974, the Circuit Criminal Court found Federico Relucio and Rosendo Velasco guilty of murder, sentencing them to reclusion perpetua and ordering joint indemnification of the victim's heirs in the amount of P12,000. The case was initiated when the City Fiscal filed an information dated May 29, 1972, stating that on June 23, 1971, both accused, alongside others, conspired to kill Gonzalo Talastas. The trial lasted from November 16, 1972, to November 5, 1973, comprising multiple sessions and a substantial amount of witness testimony.
Prosecution's Evidence
The prosecution presented multiple witnesses, notably Patrolman Jose E. Garcia and Crispin Angeles, to establish Velasco and Relucio's participation in the murder. Angeles testified that on the day of the incident, he saw Talastas leave the Capital Theater with blood on his shoulder and identified Velasco as one of the men involved in the chase and shooting. The prosecution posited that both Velasco and Padrones were in the jeep that chased Talastas, with Padrones eventually allegedly shooting Talastas.
Witness Testimony and Credibility Issues
The testimony of Crispin Angeles was central but fraught with inconsistencies and contradictions when compared to prior statements he made. For instance, discrepancies emerged regarding the sequence of events and who exactly was involved in the shooting. Angeles' initial statement contradicted his in-court testimony regarding his presence and what he observed during the events leading to Talastas' death.
Similarly, Miguel Padrones, one of the co-accused, initially presented as a witness for the prosecution, was accused of receiving leniency in exchange for his testimony. He claimed that he was forced to testify against Velasco and Relucio in order to avoid prosecution, raising queries on the motives and the integrity of his testimony.
Examination of Inconsistency
Legal principles around witness credibility and impeachment were crucial in this case. The trial revealed that both Angeles and Padrones displayed unreliable memories, and their testimonies corroborated by various documents, including police sworn statements, showed significant contradictions that undermined their reliability. Specifically, it was noted that Padrones' account, given earlier under less favorable circumstances, painted a different picture than what he later testified in court.
Court's Findings and Reasoning
The appellate court found the evidence of the prosecution, particularly the testimonies of Angeles and Padrones, to be inconsistent and unreliable. The discr
...continue readingCase Syllabus (G.R. No. L-30707)
Case Overview
- Court: Supreme Court of the Philippines
- Date: November 09, 1978
- G.R. No.: L-38790
- Citation: 175 Phil. 398; 75 OG No. 19, 4008 (May 7, 1979)
- Judgment: Reversal of conviction for murder against Rosendo Velasco
Background of the Case
- Rosendo Velasco was one of several accused in a murder case involving the death of Gonzalo Talastas.
- The Circuit Criminal Court of the Fourth Judicial District convicted him of murder on January 4, 1974, sentencing him to reclusion perpetua and to indemnify the victim's heirs.
- The other accused, Federico Relucio, withdrew his appeal and escaped from custody, making the trial court's decision final against him.
Charges and Incident Description
- The information charged Velasco and others with the murder of Gonzalo Talastas, alleging that on June 23, 1971, they conspired to kill Talastas with treachery, using firearms.
- The prosecution claimed that the accused attacked Talastas at the Capital Theater in Cabanatuan City, resulting in his death from gunshot wounds.
Trial Proceedings
- The trial included extensive testimonies over twenty-four sessions, spanning from November 16, 1972, to November 5, 1973.
- Four prosecution witnesses provided direct evidence, while additional witnesses were presented for rebuttal.
- The testimonies included conflicting accounts that were critical to establishing the accused's invo