Case Summary (G.R. No. L-62072)
Facts of the Case
The case revolves around the murder of Danilo Mangaliman, which occurred inside the New Bilibid Prison on January 16, 1977, where all parties involved were serving sentences for previous convictions. The accused conspired to attack and subsequently stab the victim following a heated argument. Renato Santos admitted to the crime by surrendering to a prison officer immediately after the stabbing. The victim was taken to the prison hospital but succumbed to his injuries the following day due to profuse hemorrhage from a stab wound in the abdomen.
Trial Court Proceedings
During the trial, Renato Santos pled guilty, whereas his co-accused pleaded not guilty. Evidence was presented, including testimonials from prison officers and a medico-legal expert, but there was a significant reliance on the eyewitness account from another inmate, Romeo Fernandez. However, Fernandez did not testify in court, which became a critical point of contention.
Admission of Hearsay Evidence
The defendants challenged their conviction on the basis that the trial court's findings were founded on hearsay evidence—specifically, the sworn statement of Romeo Fernandez, which was not subjected to cross-examination. The court observed that the right to confrontation, as enshrined in the Constitution, mandates that defendants must have the opportunity to cross-examine witnesses against them. The reliance on hearsay evidence constituted a significant violation of their constitutional rights.
Evaluation of Evidence
The Supreme Court reviewed the testimonies of witnesses presented by the prosecution, concluding that none implicated the co-accused directly in the crime. The case against the co-accused was built largely on unsupported affiliations to Santos's actions. The court noted that while Santos confessed to inflicting the fatal stab wound, there was no evidence supporting any conspiracy among the co-accused with him during the crime.
Acquittal of Co-Accused
Due to the lack of direct evidence linking the co-accused to the murder, their convictions were overturned, leading to thei
...continue readingCase Syllabus (G.R. No. L-62072)
Case Overview
- The case involves a mandatory review of the death sentence imposed by the then Circuit Criminal Court of Rizal upon the defendants Renato Santos, Romeo Gutierrez, Antonio Juaningo, Alfredo Gonzales, Joseph Lanuza, and Jose Perez for the murder of Danilo Mangaliman.
- The decision was rendered on November 11, 1985, by the Supreme Court of the Philippines.
- The primary legal issue revolves around the constitutionality of the conviction based on hearsay evidence.
Facts of the Case
- The crime occurred on January 16, 1977, inside the New Bilibid Prison in Muntinlupa, Rizal, where all parties involved were serving sentences for previous convictions.
- Danilo Mangaliman was fatally stabbed by Renato Santos following a heated argument.
- An autopsy conducted by Dr. Ampil confirmed that Mangaliman died from profuse hemorrhage due to a stab wound in the abdomen.
- Following the incident, Renato Santos surrendered and confessed to the crime to a prison officer.
Trial Proceedings
- At arraignment, Renato Santos pleaded guilty, while the other accused pleaded not guilty.
- The prosecution's primary evidence included the affidavit of an eyewitne