Title
Tadeja vs. People
Case
G.R. No. 145336
Decision Date
Feb 20, 2013
A 1994 fiesta homicide case where petitioners were convicted; final judgment upheld despite a co-accused’s later confession, as it failed to meet newly discovered evidence criteria.
murder
prosecution witnesses
trial
A

Case Summary (G.R. No. 145336)

Factual Background of the Killing

The trial court found that prosecution witnesses Maria Elena Bernardo Almaria (“Elena”) and Jacinta del Fierro (“Jacinta”) were watching a public dance at the barangay during the fiesta. At about midnight on 3 May 1994, they allegedly witnessed Ruben Bernardo being hacked to death by Reynante, Ricky, Ricardo, and Ferdinand, together with Plaridel Tadeja (all surnamed Tadeja). The witnesses further testified that Plaridel accidentally hit Reynante while attempting to hack Ruben, thereby causing Reynante’s injuries. They claimed they remained at the scene until Ruben was brought to the hospital.

Petitioners, however, presented a different version. They alleged that Ruben and his sons, Russell and Robenson Bernardo, went to the barangay plaza after Russell had been twice prevented by barangay tanods from entering the dance hall because of his drunken state and lack of an upper garment. Petitioners testified that Ruben was brandishing a knife and cursing at the crowd. They claimed that Ruben challenged Reynante, who was waiting for his children and sisters inside the dance hall. Petitioners maintained that Reynante’s brothers—Ricky, Ricardo, and Ferdinand—were together at their mother’s house at the time. Reynante allegedly evaded an initial knife attack by Ruben. The barangay chairperson attempted to intervene but was threatened, after which Ruben allegedly chased Reynante when Reynante tried to run away. Petitioners claimed that Russell and Robenson blocked Reynante’s path, causing him to fall, and then attacked him. Petitioners’ narrative stated that Ruben seized Reynante’s right hand, ordered his sons to run away, and stabbed Reynante on the right chest and left side. Petitioners added that Reynante struggled back to the plaza, was taken to the hospital in a jeep, and that while traveling they saw Ruben about fifteen meters away still holding a knife. Eddie Eraso allegedly reported the incident to the police, and police officer Ronaldo Flores went to the hospital to question Reynante. Reynante’s questioning was interrupted when Ruben arrived at the emergency room in serious condition. Ruben later died of hypovolemic shock due to acute blood loss from multiple stab wounds and a hacking wound.

Subsequently, an official signal dispatch was sent on 4 May 1994 based on Reynante’s account that he had arrived to fetch his children, was chased by Ruben, and was stabbed by Ruben when he lost balance.

Related Criminal Cases and Trial Court Disposition

On 15 July 1994, an Information for homicide for Ruben’s death was filed against Reynante, Ricky, Ricardo, Ferdinand, and Plaridel, docketed as Criminal Case No. Z-814 before the Regional Trial Court (RTC), Branch 44, Mamburao, Occidental Mindoro. On the same date, Reynante filed a complaint for frustrated homicide against Russell and Robenson, docketed as Criminal Case No. Z-815 before the same RTC. The cases were tried jointly.

In Criminal Case No. Z-814, the RTC issued its Decision on 15 July 1997, finding Reynante, Ferdinand, Plaridel, Ricardo, and Ricky guilty beyond reasonable doubt of homicide. It imposed an indeterminate penalty from six years and one day of prision mayor as minimum to fourteen years, eight months, and one day of reclusion temporal as maximum, and ordered them to indemnify the heirs of Ruben in the amount of P50,000, plus costs. In Criminal Case No. Z-815, the RTC acquitted Russell and Robenson of frustrated homicide in a 14 July 1997 Decision. Plaridel absconded, but all other accused appealed.

Appellate Review and Petitioners’ Arguments

The Court of Appeals issued its Decision on 8 March 2000 in CA-G.R. CR No. 21740, affirming the RTC’s conviction. The CA held that although the prosecution witnesses were relatives of the victim, they lacked any evil motive to testify falsely. It also found that Ruben’s injuries matched the stab wounds described by Elena and Jacinta. The CA rejected the defense that Reynante and Plaridel were allegedly asleep at their mother’s house by noting the short distance to the crime scene and the feasibility of attendance within minutes by foot or tricycle. The CA further found conspiracy properly appreciated by the RTC, and it did not give credence to claimed inconsistencies among petitioners’ narratives regarding what happened at the incident. In particular, the CA viewed the defenses of Reynante and Plaridel as confusing. It noted that both claimed Ruben chased and stabbed them, and it questioned the credibility of the account that Plaridel was not hurt despite an alleged attack by Ruben that, according to the defense, involved weapons and accompaniment by the Bernardos.

Petitioners moved for reconsideration and submitted transcripts of additional witnesses, namely Leticia Bernardo, Maria Regina Cortuna (“Regina”), and Eduardo Eraso. Petitioners believed that these witnesses, whose testimonies they said were missing in the records forwarded to the CA in Z-814 (although they were presented in Z-815), would debunk the RTC’s basis for conviction. Petitioners stressed Regina’s testimony that Elena and Jacinta were at Lola Tinays house that night and only later at another house, where Ruben was said to be already wounded. Petitioners also questioned the credibility of Elena and Jacinta by noting the alleged delay in their testimony and lack of immediate statements to aid recollection. They also invoked alibi as a “plain and simple” truth in the circumstances.

When required to comment, the Office of the Solicitor General countered that witness testimony may be believed in part or disbelieved in another, based on corroboration and probabilities, and that the RTC retained discretion to accept or reject evidence. The OSG also rejected the argument that the mere nature of the witnesses as relatives automatically implied bias, and it explained that victims and their relatives naturally observe assailants and crime details. It stated that while flight could indicate guilt, petitioners’ non-flight had no jurisprudential basis for proving innocence.

This Court, by Decision dated 21 July 2006, affirmed the CA. It held that the CA should have considered the “totality of evidence” from Z-814 and Z-815, yet it found that the testimonies of Leticia, Regina, and Eduardo would not have altered the judgment. It ruled that Regina’s testimony did not negate the existence of witnesses to the incident or establish that Ruben was alone at the time. The Court also reasoned that blood relationship could even fortify credibility, because it would be unnatural for an aggrieved relative to falsely accuse an innocent person other than the actual culprit. As to alibi, the Court found it not physically impossible for the accused to be at the scene. Petitioners’ motion for reconsideration was denied with finality on 23 October 2006.

Motions to Vacate and the Claimed Newly Discovered Evidence

After finality, petitioners filed a Motion with Leave of Court to Vacate Judgment on 6 November 2006, invoking the Court’s power to suspend rules for substantial justice and to remand the case for further reception of evidence. Petitioners attached sworn statements of Maryjane Togas, Dennis Laudiangco, Heneroso Anoba, and Francisco de Veyra, Jr. that generally corroborated Reynante’s account that Ruben chased and stabbed Reynante when Reynante lost footing. The affidavits added that Reynante was aided by Plaridel, who allegedly slashed Ruben in the neck and stabbed him repeatedly until he fell. They also claimed that Plaridel left the scene and that people brought both individuals to the hospital. The affiants stated that Ricky, Ricardo, and Ferdinand were not present during the incident and that they stepped forward only later out of fear of reprisal by Plaridel, whom they described as a known criminal. Petitioners further attached a Pinagsamang Salaysay signed by 228 residents attesting to their innocence.

Petitioners then filed a Supplemental Motion alleging a supervening event: on 29 November 2006, Plaridel was allegedly arrested after being a long-time wanted person. They attached a Spot Report Re Apprehension of a Long Time Wanted Person, and a statement executed by Plaridel with the assistance of Atty. Cirilo Tejoso, Jr. admitting that he killed Ruben. In that statement, Plaridel narrated that on 3 May 1994 he was at Highway, Talabaan, looking for his child, when he saw his first cousin Reynante being chased by Ruben; he allegedly aided Reynante by grabbing Ruben’s knife and stabbing Ruben with it. Plaridel claimed that Reynante was transported to the hospital, and that he left Ruben on the road and followed Reynante. Plaridel also stated that he did not know why Ruben chased Reynante with a knife, and he claimed that he did not see Ricardo, Ricky, or Ferdinand at the scene. He said he later admitted the crime because he allegedly feared and absconded during the trial. Petitioners argued that the confession and apprehension after trial satisfied the rules on newly discovered evidence and warranted reopening and remand for a new trial.

The Court treated petitioners’ motion to vacate judgment as a prohibited second motion for reconsideration and denied it by noting the procedural bar. It also stated that it would take no further action on the supplemental motion and directed entry of judgment. Petitioners later argued that their motion to vacate judgment was different from the previously resolved issues and that the relief prayed for should permit reopening. The Court denied the subsequent motions with finality for lack of merit. It recorded the Decision’s finality in the Book of Entries of Judgments on 26 July 2007.

Post-Finality Letters and Requests to Reopen the Case

After finality, Ferdinand separately sought reopening by letter dated 7 August 2007, invoking Plaridel’s confession, and the Court required the OSG to comment. The OSG responded that it posed no objection. Ferdinand also requested suspension of execution pending

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