Title
People vs. Tulagan
Case
G.R. No. L-68620
Decision Date
Jul 22, 1986
A 1979 stabbing during a chase led to Romie Mendoza's murder conviction, overturned by the Supreme Court due to insufficient evidence and inadmissible testimony.
murder case
witness testimony
circumstantial evidence
A

Case Summary (G.R. No. L-68620)

Factual Background: The Killing During a Barangay Fiesta Chase

The prosecution and defense agreed that the deceased was killed while attempting to flee from at least two identified men: Freddie (or Eding) Tulagan and Valentin “Satsoy” de Guzman. The chase began at or near the public hall of Barangay Don Pedro, Malasiqui, Pangasinan, where a dance was being held for the barrio fiesta. It ended about three hundred meters away at the porch (azotea) of the house of Cesar Evangelista. The fatal wound was a single stab wound described in the autopsy report as elliptical, about one and one-half inches long, located about one inch from the left para-sternal region at the level of the fifth intercostal space, directed upward, penetrating the upper portion of the anterior lobe of the left lung and the ascending portion of the aorta.

No one testified to the precise manner, exact location of the fatal act, or the specific person who inflicted the single lethal stab wound. The record reflected that the victim was killed during the pursuit, but the evidentiary gaps extended to who, among the pursuers, actually delivered the fatal blow, and what roles the others played at the critical moment.

The Prosecution’s Evidence: Bonifacio Ulanday and Natalia Macaraeg

The prosecution relied heavily on the testimony of Bonifacio Ulanday, the only person claimed to have direct observation of the pursuit’s progression and its aftermath. He gave a sworn statement before the Provincial Fiscal at Dagupan City on June 6, 1979 and later testified at trial. Ulanday recounted that the chase started after the deceased was accosted at the dance hall by Valentin de Guzman alias “Satsoy” and three others. He stated that the deceased ran when “Satsoy” obtained a balisong and that “Satsoy chased Marlon Catungal,” while the other companions also chased the victim. Ulanday followed approximately fifteen meters behind and then lost sight when the victim entered a yard. Crucially, he stated he never saw any person stab or kill Marlon Catungal.

Ulanday testified that he only saw four persons lift and place the victim’s corpse in front of the large house, with the victim “motionless” and blood oozing. He also asserted that in his sworn statement he saw “Satsoy and his companions” carrying the cadaver from the azotea of a house located around ten meters away from the road and placing it on the left side of the road. Yet, the testimony and the sworn statement did not establish who inflicted the stab wound, nor whether all accused participated in the final assault.

The other key prosecution witness was Natalia Macaraeg, the barangay captain’s daughter. The Trial Court treated her testimony as establishing an incriminating statement by Valentin “Satsoy” de Guzman, which the Trial Court characterized as part of the res gestae or an “oral confession.” The Court relied on her account that she asked Vicente de Guzman, Freddie Tulagan, and Romeo Mendoza about what they did to her neighbor working with the PNR, and she said that Vicente de Guzman told her “we killed him,” and related that they “ran after” the PNR neighbor.

Filing of the Information and the Conviction of Romeo “Romie” Mendoza

On the basis of the sworn statements of Ulanday and those of Barangay Captain Jose B. Macaraeg and his daughter Natalia, an information was filed with the Circuit Criminal Court at Dagupan City. The charging allegations asserted conspiracy, intent to kill, evident premeditation, and taking advantage of superior strength. However, the information did not supply direct factual proof that “Satsoy” stabbed the victim while the deceased was being held “helpless and defenseless” by the other accused.

From the four charged, only Romeo “Romie” Mendoza was arrested. He pleaded not guilty. After trial, he was convicted of murder under Article 248 of the Revised Penal Code, with one generic aggravating circumstance and no mitigating circumstance. He was sentenced to the supreme penalty of death, and ordered to pay damages, including P30,000.00 indemnity, P15,000.00 moral damages, and P15,000.00 exemplary damages, together with burial-related amounts and costs. The case was archived as to the other accused pending arrest.

Trial Court’s Reasoning: Res Gestae and Inferential Circumstances

In reviewing the conviction, the Supreme Court identified material legal error in how the Trial Court treated Natalia Macaraeg’s testimony. The Trial Court held that de Guzman’s statement was admissible against Romeo Mendoza as res gestae under Section 36, Rule 130, and alternatively as an oral confession.

The Trial Court further treated as incriminating the alleged failure of Romeo Mendoza to deny “certain circumstances and pieces of evidence.” It concluded that when the accused returned to Natalia’s store around 10:30 PM, Natalia noticed blood stains on their hands and bodies, and that these circumstances were “conclusive and decisive” evidence of Romeo Mendoza’s guilt.

The Supreme Court found these conclusions unsupported by the record and internally inconsistent with the Trial Court’s own narrative.

Supreme Court’s Ruling on Evidentiary Admissibility: Error on Res Gestae

The Supreme Court held that the statement attributed to Valentin de Guzman alias “Satsoy” was not admissible as part of the res gestae as used by the Trial Court against Romeo Mendoza. The Court reasoned that the record did not show that the statement was made immediately subsequent to the startling occurrence—the slaying—within the contemplation of Rule 130, Section 36. Ulanday’s account suggested the pursuit could have lasted about almost one hour, and Natalia herself testified that the accused returned to her store at about 10:30 PM, after “more or less 1 1/2 hours.”

The Supreme Court emphasized the doctrinal requirement that only statements spontaneously and involuntarily extracted by the shock of the occurrence qualify as res gestae; the event must “speak through the witness.” The Court found no indication that de Guzman was agitated or stunned when he made the statement. Instead, Natalia’s testimony portrayed him as calm and fully aware of what he said and did. On those facts, the Trial Court’s res gestae characterization was erroneous.

As an oral confession, the Supreme Court recognized that the statement was admissible only against the confessing person, Valentin de Guzman, and could not be used against other accused persons. The Court invoked the rule of res inter alios acta, which proscribes using a co-accused’s confession against another accused in the absence of qualifying admissibility.

Supreme Court’s Treatment of Alleged Silence and Failure to Deny

The Supreme Court also rejected the Trial Court’s conclusion that Romeo Mendoza’s alleged failure to deny certain circumstances proved his guilt. The Supreme Court pointed out that the Trial Court itself had elsewhere noted that Romeo Mendoza denied the testimony of Ulanday that he chased the deceased. It also demonstrated that Romeo Mendoza specifically denied visiting Natalia’s store with blood-stained hands with Tulagan and de Guzman, and the record contained the accused’s testimony that he did not go to the store on the night of the killing and that the accusation about blood stains was untrue.

The Supreme Court further held that the Trial Court’s use of the interval between issuance of a warrant and actual arrest—about two years—was illogical as evidence of guilt. The Court reasoned that the lapse of time, standing alone, did not establish deliberate evasion of arrest. It noted documentary references indicating an unserved arrest order due to inability to locate the accused at the given address and later reports of changes in residence for other co-accused. However, the Supreme Court found those documents inadequate to prove that Romeo Mendoza hid himself or deliberately eluded arrest, and it highlighted that his eventual arrest occurred in Malasiqui, consistent with residence there, undermining the inference of hiding in an undisclosed place.

Qualifying Circumstance of Abuse of Superior Strength: Unsupported by the Record

The Supreme Court further found error in the Trial Court’s conclusion that the killing was qualified by abuse of superior strength. The Court reasoned that the record lacked direct evidence on who inflicted the single fatal stab wound, on whether all pursuers participated in the final assault, and on what each accused was doing at the critical time. In the absence of evidentiary basis establishing the manner in which the victim was held or overpowered by superior strength at the moment of stabbing, the Court held that the Trial Court’s finding was speculative rather than grounded on proof.

Credibility Concerns: Natalia Macaraeg and Bonifacio Ulanday

Beyond legal errors on admissibility and qualifying circumstances, the Supreme Court subjected the principal prosecution witnesses’ credibility to strict scrutiny and found serious defects.

Concerning Natalia Macaraeg, the Court noted that she omitted in two sworn statements—dated May 21, 1979 and June 6, 1979—the alleged admission by de Guzman that “we killed” Marlon Catungal. The Court observed that only when she testified much later, on May 29, 1982, did she make that revelation. Her explanation that she did not like trouble was deemed unconvincing. The Court reasoned that if she feared retaliation, she would not have given statements at all, and even without the confession detail, her earlier statements already implicated the accused and exposed her to possible reprisal.

The Court also found Natalia’s conduct inconsistent with her narrative. According to her, de Guzman and companions first appeared to announce an intention to go after the man who chased de Guzman’s father, and later returned to proclaim that their purpose had been accomplished. The Court considered such conduct unnatural for perpetrators who would ordinarily conceal a killing, thus diminishing reliability.

As to Bonifacio Ulanday, the Sup

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