G.R. No. 121039-45 - People vs. Sanchez

Case Summary (G.R. No. 121039-45)

Petitioner and Respondent

Petitioner (in the motions for reconsideration before the Supreme Court): the accused-appellants seeking reconsideration of the Court’s January 25, 1999 affirmation of the trial court’s conviction. Respondent: The People of the Philippines, represented by the Office of the Solicitor General (which filed a Comment on December 6, 1999).

Key Dates

Trial court conviction and original sentencing (as recorded in the appealed judgment). Supreme Court decision affirming conviction: January 25, 1999. Motions for reconsideration filed by accused-appellants (timely for some appellants); OSG Comment filed December 6, 1999. Justice Martinez retired February 2, 1999; administrative reassignment of the motions issued under A.M. No. 99-8-09; motions for reconsideration were assigned by raffle on September 18, 2001. Supreme Court resolution on the motions for reconsideration: October 18, 2001.

Applicable Law

Constitutional framework: 1987 Constitution (Bill of Rights) — notably the right to a fair trial and freedom of the press, which are balanced where pervasive publicity is alleged to have prejudiced trial proceedings. Substantive criminal law: elements and penalties for rape with homicide; sentencing of reclusion perpetua for each count. Civil damages and compensatory principles: Civil Code Article on moral damages (Article 2216 referenced), jurisprudential standards for proof of actual or compensatory damages (People v. Timon; People v. Nablo), and formulae for computing loss of earning capacity (Villa Rey Transit formula using American Expectancy Table of Mortality). Governing appellate principles on witness credibility and impeachment and the burden to show actual prejudice from pretrial publicity were applied and drawn from prior jurisprudence cited in the decision.

Procedural History and Relief Sought

The trial court convicted the accused for seven counts of rape with homicide and awarded substantial civil damages to the heirs of Eileen Sarmenta and Allan Gomez. The Supreme Court previously affirmed that conviction on January 25, 1999. Accused-appellants filed motions for reconsideration advancing mainly: (1) denial of impartial trial due to prejudicial publicity; (2) lack of credibility or successful impeachment of principal prosecution witnesses (Centeno and Malabanan); (3) validity and sufficiency of alibi testimony (notably Mayor Sanchez’s daughter); and (4) excessiveness or lack of factual basis for civil damages awarded. The Supreme Court (Melo, J., ponente) resolved the motions for reconsideration.

Issues Presented

Whether pervasive media publicity deprived the accused of a fair and impartial trial.
Whether principal prosecution witnesses were properly found credible and whether prior inconsistent statements impeached their testimony on material points.
Whether the alibi evidence (including testimony of a 13-year-old daughter) sufficed to overturn the convictions.
Whether the trial court’s awards of actual, moral, funeral, loss-of-earning-capacity, and attorney’s fees/litigation expenses were supported by evidence and the law, and whether any double recovery occurred.

Court’s Analysis — Prejudicial Publicity and Fair Trial

The Court applied the established test requiring proof of actual prejudice to the trial judge, rather than mere possibility of prejudice from extensive publicity. The Court recognized the constitutional tension between freedom of the press and the accused’s right to a fair trial but emphasized that responsible reporting is not incompatible with fair adjudication. The accused bore the burden to prove that the trial judge or the appellate tribunal had been unduly influenced by media coverage. The records, as reviewed by the trial court and the Court, did not demonstrate actual bias or that the trial judge had developed a fixed position incapable of being changed by evidence at trial. Accordingly, the claim of trial or conviction by publicity was rejected.

Court’s Analysis — Credibility of Prosecution Witnesses and Impeachment

The Court reiterated that appellate courts defer to trial courts on credibility determinations because trial judges witness demeanor and testifying conduct firsthand. The trial court had found Centeno and Malabanan to be frank, spontaneous, and consistent on substantive matters despite vigorous cross‑examination. Alleged inconsistencies were examined and deemed minor or collateral; where testimony accords on material points, inconsequential contradictions do not destroy credibility. The accused did not present new evidence in the motions for reconsideration to alter that conclusion. Consequently, the Court sustained the trial court’s credibility findings and rejected the impeachment arguments.

Court’s Analysis — Alibi Defense

The Court reiterated the well-established rule that alibi is a weak defense, especially where its support rests primarily on testimony from a relative. Although statements of children may carry probative value, the daughter’s testimony was insufficient to overcome the positive declarations of prosecution witnesses who placed Mayor Sanchez at the crime scene. Other accused-appellants’ alibis fared worse because they lacked corroboration. The Court therefore found the alibi claims unavailing.

Court’s Analysis — Double Recovery and Civil Indemnity Deduction

The trial court had already included P50,000.00 civil indemnity per death in the amounts awarded as actual damages. The Supreme Court noted that ordering an additional P350,000.00 (P50,000.00 per count for seven counts) without deducting the civil indemnity already counted in actual damages would result in double recovery for the heirs. The Court therefore required the deduction of the P50,000.00 already included in the trial court’s computation from the amounts constituting actual damages so as to avoid duplicative awards.

Court’s Analysis — Funeral Expenses

The trial court awarded funeral expenses to both families; the Sarmenta family supported their award with appropriate receipts, while the Gomez family did not produce receipted evidence. The Court applied the rule that burial or funeral expenses are compensatory actual expenses which must be proved by receipts or other proof. Accordingly, the Sarmenta family’s funeral expense award (P106,650.00) was sustained; the Gomez family’s P74,000.00 award was deleted for lack of proof and replaced by nominal damages of P10,000.00 to recognize the violation of rights even absent proof of a specific amount.

Court’s Analysis — Loss of Earning Capacity

The trial court had awarded large amounts for the loss of earning capacity (P3,276,000.00 for Sarmenta and P3,360,000.00 for Gomez) based on assumed monthly earnings of P15,000.00 and deductions for living expenses of P8,000.00, applying life expectancy figures from the American Expectancy Table of Mortality. The Supreme Court recognized that loss of earning capacity can be awarded even if the deceased was not gainfully employed at the time of death, but it emphasized that awards cannot rest on mere speculation. Testimony by the victims’ mothers suggesting P10,000–P15,000.00 monthly income was speculative and insufficiently supported. Considering the victims were senior agriculture students at a leading university and could reasonably be expected to earn above the minimum wage upon graduation, the Court found a more conservative and defensible assumption appropriate: a 1993 gross monthly income of P8,000.00 with living and incidental expenses of P3,000.00 monthly (P96,000.00 and P36,000.00 annually, respectively). Using the Villa Rey Transit formula and the American Expectancy Table, the Court recalculated net earning capacity as follows:

Heirs of Eileen Sarmenta: 2/3(80-21) × (96,000 – 36,000) = 39.353 × 60,000 = P2,361,180.00
Heirs of Allan Gomez: 2/3(80-19) × (96,000 – 36,000) = 40.687 × 60,000 = P2,441,220.00

These adjusted amounts replaced the trial court’s higher awards.

Court’s Analysis — Moral Damages

The Court reviewed the trial court’s award of P2,000,000.00 in moral damages to each family and determined the amounts excessive. Moral damages are reparatory, intended to provide relief proportionate to the suffering inflicted and not to punish or enrich the claimant. Applying Article 2216 of the Civil Code and relevant jurisprudence, the Court exercised its discretion to reduce the moral damages to P1,000,000.00 for each set of heirs (Sarmenta and Gomez).

Attorney’s Fees and Litigation Expenses

The Court found the awards for attorney’s fees and litigation expenses reasona

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Case Syllabus (G.R. No. 121039-45)

Citation, Court and Panel

Reported at 419 Phil. 808, Special First Division, G.R. Nos. 121039-45, decided October 18, 2001.
Resolution authored by Justice Melo, J.; Chief Justice Davide, Jr. (Chairman), and Justices Kapunan and Pardo concurred.
The matter is a motion for reconsideration of the Court's January 25, 1999 decision (penned by Justice Antonio M. Martinez) which affirmed in toto the judgment of conviction of the Pasig City Regional Trial Court, Branch 70.

Parties and Lower Court Disposition

Plaintiff-Appellee: The People of the Philippines.
Accused-Appellants: Mayor Antonio L. Sanchez, George Medialdea, Zoilo Ama, Baldwin Brion, Luis Corcolon, Rogelio Corcolon, and Pepito Kawit.
The trial court found the accused guilty beyond reasonable doubt of seven counts of rape with homicide and imposed reclusion perpetua for each count, with various civil awards to the heirs of the two victims.
The January 25, 1999 decision affirmed the conviction and the lower court's awards, and additionally ordered each accused to pay the amount of Seven Hundred Thousand Pesos (P700,000.00) to the heirs of the two victims as additional indemnity (subject to later modification in the present resolution).

Procedural History and Motions

Accused-appellants Antonio Sanchez, Zoilo Ama, Baldwin Brion and Pepito Kawit filed motions for reconsideration of the January 25, 1999 decision.
The Office of the Solicitor General filed its Comment on December 6, 1999.
Justice Martinez retired on February 2, 1999; by A.M. No. 99-8-09 the motions were reassigned by raffle on September 18, 2001 to the present ponente (Justice Melo) for study and preparation of appropriate action.

Issues Raised on Reconsideration

Mayor Antonio Sanchez alleged (a) trial and conviction by pervasive publicity, (b) lack of credibility of prosecution witnesses Aurelio Centeno and Vicencio Malabanan, (c) that his 13‑year-old daughter’s testimony as to his whereabouts should prevail as an alibi over prosecution evidence, and (d) that the quantum of damages awarded was "gargantuan" and without factual or legal basis.
Accused-appellants Zoilo Ama, Baldwin Brion, and Pepito Kawit contended that prosecution witnesses Centeno and Malabanan were sufficiently impeached by prior inconsistent statements on material points and that independent and disinterested witnesses destroyed the prosecution’s version of events.
The Court observed that, except for the damages issue raised by Mayor Sanchez, the motions presented no new issues different from those previously raised and passed upon by the trial court and this Court.

Standard on Alleged Prejudicial Publicity

The Court reiterated the rule from People vs. Teehankee, Jr. that pervasive publicity is not per se prejudicial to an accused’s right to a fair trial and emphasized the role of a responsible press as compatible with fair trial rights.
The Court explained that the correct test is actual prejudice: there must be allegation and proof that judges were unduly influenced by publicity, not merely a showing that they might have been (citing Martelino et al. vs. Alejandro et al.).
The burden to prove actual bias rests on the accused; Mayor Sanchez failed to present proof that the trial judge or the Court were actually biased by publicity.
The Court concluded that the record does not establish that the trial judge acquired a fixed position incapable of change or that this Court was unduly swayed by publicity.

Credibility of Prosecution Witnesses (Centeno and Malabanan)

The Court reaffirmed the hornbook doctrine that appellate courts will not disturb trial court findings on witness credibility because the trial court is in the best position to observe witness deportment and manner of testifying (citing People vs. Mendoza).
Then Judge Harriet Demetriou found Centeno and Malabanan to have testified in a frank, spontaneous, and straightforward manner, with testimony that did not waver on substantial matters despite gruelling cross-examination.
Alleged prior inconsistencies were examined by both the trial court and this Court and were found to pertain to minor and collateral matters; the Court cited People vs. Agomo-o for the rule that inconsequential inconsistencies do not dilute credibility when witnesses agree on substantial matters.
Accused-appellants failed to present new evidence in their motions for reconsideration that would justify disregarding these credibility determinations or show that the Court overlooked, misunderstood, or misapplied material facts.

Alibi Defense and the Daughter's Testimony

The Court acknowledged that statements of children are accorded great probative value but emphasized that alibi is the weakest defense and that an alibi supported only by the testimony of a relative deserves scant consideration (citing Pe