People v. Amparado
REITERATIONFacts
The Antecedents: Accused-appellant Norman Amparado was found guilty of Murder for the death of Manuel Maghanoy by the Court of First Instance of Zamboanga del Norte, Branch 1, Dipolog City. He was sentenced to reclusion perpetua and to pay civil indemnity. This Court affirmed the judgment with modification on the civil liability. Procedural History: The accused-appellant filed a motion for a new trial, citing the discovery of new and material evidence, errors of law or irregularities during trial, and the interest of substantial justice. The People of the Philippines opposed the motion. The Petition: The accused-appellant sought a new trial based on the testimonies of Antonio Cachin Jr. and Manuel Henry Auza, who allegedly were the first persons to render assistance to the victim immediately after the stabbing incident. The accused-appellant claimed these testimonies would show that the prosecution's alleged eyewitness, Rogelio Patangan, was not present at the scene of the crime. The accused-appellant also detailed the efforts made to discover this evidence and the reasons why it could not be presented during the trial, including fear of retaliation.
Issue(s)
Whether the testimonies of Antonio Cachin Jr. and Manuel Henry Auza constitute newly-discovered evidence. Whether the said testimonies are of sufficient weight and character to alter the outcome of the case. Whether the accused-appellant exercised reasonable diligence in discovering the evidence.
Ruling
The Court Resolved to GRANT the accused-appellant's motion for new trial. The judgment of this Court dated October 3, 1985, and the judgment of the trial court dated April 11, 1978, were reconsidered and set aside. The records of the case were remanded to the lower court for a new trial.
Ratio Decidendi
On whether the testimonies of Antonio Cachin Jr. and Manuel Henry Auza constitute newly-discovered evidence: The Court found that the evidence sought to be presented was newly-discovered as defined by the Rules of Court. The accused-appellant's affidavit detailed his efforts to locate witnesses and explained why he could not have discovered these particular witnesses earlier, citing fear of retaliation and his absence from the scene after the incident. He only learned of their presence and their willingness to testify after receiving a copy of the Supreme Court's decision and subsequently meeting a prosecution witness who mentioned Cachin Jr. and Auza's presence. On whether the said testimonies are of sufficient weight and character to alter the outcome of the case: The Court determined that the proposed testimonies of Antonio Cachin Jr. and Manuel Henry Auza, who averred to be the first persons to render assistance to the victim immediately after the stabbing incident, were of sufficient weight and character to alter the outcome. If admitted, these testimonies would tend to show that the alleged eyewitness Rogelio Patangan, whose version of the crime was given full faith and credence by the trial court and sustained by the Supreme Court, was not present at the scene of the crime. This, in turn, could lead to the failure of the prosecution's version and the prevalence of the defense's version, potentially reversing or modifying the judgment of conviction. On whether the accused-appellant exercised reasonable diligence in discovering the evidence: The Court found that the accused-appellant's explanation for not presenting these witnesses during the trial was credible. He stated that he did not know of their existence at the time and that he did not return to the scene of the incident to gather information due to fear of retaliation from the victim's relatives and friends. His discovery of these witnesses only occurred after the Supreme Court's decision, when he sought legal advice and coincidentally met a prosecution witness who provided the crucial information.
Main Doctrine
A motion for new trial based on newly-discovered evidence may be granted if such evidence, if admitted, would tend to alter the outcome of the case and was discovered despite the exercise of reasonable diligence.