People v. Velasco
REITERATIONFacts
The Antecedents: The accused, including appellant Rosendo Velasco, were charged with murder for the killing of Gonzalo Talastas. The information alleged conspiracy, treachery, evident premeditation, and cruelty. Procedural History: The Circuit Criminal Court of the Fourth Judicial District found Federico Relucio and Rosendo Velasco guilty of murder and sentenced them to reclusion perpetua. Federico Relucio withdrew his appeal. Rosendo Velasco appealed the decision. The Petition: Appellant Rosendo Velasco appealed his conviction, arguing that the evidence presented against him was insufficient and unreliable.
Issue(s)
Whether the testimony of Crispin Angeles is sufficient to establish the guilt of the appellant beyond reasonable doubt despite his prior inconsistent statement. Whether the discharge and testimony of Miguel Padrones as a state witness was valid and credible given the inconsistencies and alleged suppression of his prior statements.
Ruling
The Supreme Court reversed the decision of the trial court, acquitting appellant Rosendo Velasco due to lack of sufficient evidence. The Court ordered his immediate release unless detained for other lawful causes.
Ratio Decidendi
On Issue 1: The Court ruled that the testimony of Crispin Angeles was completely discredited. Applying United States v. Baluyot, the Court noted that while the defense failed to strictly 'lay the predicate' by asking Angeles to explain his prior inconsistent statement (Exhibit 17), the prosecution waived this requirement by failing to object to the statement's introduction. The Court found the discrepancies between Angeles's court testimony and his sworn statement to be 'utterly beyond possible rational explanation.' In court, he claimed he did not see the shooter inside the theater, but in Exhibit 17, he claimed he saw Relucio and Talastas trade shots. Because the versions were so disparate, the Court held it had no alternative but to reject both, as the witness clearly lied in at least one of them. On Issue 2: The Court found the discharge and testimony of Miguel Padrones to be highly irregular and untrustworthy. Under Rule 119, Section 9 (now Section 17), a state witness must not appear to be the 'most guilty,' yet earlier statements (including those of Angeles) suggested Padrones was the one who actually shot the victim with a carbine as he lay falling. Furthermore, Padrones exhibited 'selective' poor memory on the stand, particularly regarding a statement he executed before Judge Alfin Vicencio on October 5, 1972. The Court observed that the prosecution and the trial judge appeared to suppress the existence of this statement, which defense counsel and even Judge Vicencio himself confirmed. The Court concluded that Padrones's testimony was tailored to pin the blame on Velasco while exonerating himself, and given the inconsistencies regarding dates and administering officers, his credibility was non-existent.
Main Doctrine
The testimony of a witness, particularly a discharged co-accused, which is riddled with inconsistencies and contradictions, especially when impeached by a prior sworn statement, cannot be the sole basis for conviction, particularly when the prosecution fails to present other corroborating evidence.