People v. Narajos
REITERATIONFacts
The Antecedents: On September 12, 1976, in Tacurong, Sultan Kudarat, the accused Gregorio Narajos and Uldarico Prado were charged with Murder for allegedly conspiring, confederating, and mutually helping each other to attack and stab Enrico Garzon with a knife, inflicting a mortal wound that caused his death. The information alleged treachery and evident premeditation, with aggravating circumstances of superior strength and nocturnity, and that the crime was committed at the victim's residence. The incident stemmed from a prior tumultuous affray between relatives of the accused and the victim's group concerning hospital bills. While the victim, Enrico Garzon, was conversing with his wife and driver on his veranda, Uldarico Prado arrived and questioned why Narajos should pay the hospital bills. Narajos then appeared and immediately stabbed Garzon on the right chest. Garzon attempted to prevent further penetration by holding the knife, sustaining a wound on his left hand. He then pulled the blade out and fell. Narajos also fell and tried to retrieve the blade. While Garzon was striking the ground with the blade to keep Narajos away, Prado strangled him. Alejandro Gonzales intervened, and the accused fled. Garzon was brought to the hospital where he died on September 16, 1976, due to the stab wound. Procedural History: The Regional Trial Court of Tacurong, Sultan Kudarat, Branch XX, found Gregorio Narajos guilty of Murder and sentenced him to reclusion perpetua, to indemnify the heirs of Enrico Garzon, and to pay costs. Uldarico Prado remained at large. Gregorio Narajos appealed the decision. The Petition: The accused-appellant raised several assignments of error, primarily questioning the trial court's assessment of evidence due to a change of judge and alleged inconsistencies in prosecution testimonies.
Issue(s)
Whether the trial court erred in allowing a judge who did not hear all the testimonies to render the decision. Whether the trial court erred in accepting the prosecution's version and rejecting the defense's version of the incident, including alleged inconsistencies in prosecution testimonies, credibility of witnesses, and delay in giving statements. Whether the trial court erred in its appreciation and evaluation of the evidence, considering the flight of a co-accused. Whether the trial court erred in convicting the accused-appellant based on the totality of the evidence.
Ruling
The Supreme Court affirmed the judgment of the Regional Trial Court with modification, increasing the indemnity to P30,000.00.
Ratio Decidendi
On the issue of the judge who rendered the decision: The Court held that a judge may validly render a decision even if they only partly heard the testimony of witnesses. This is permissible when the judge who tried the case resigns, dies, or retires, and the successor can render judgment based on the cold record, similar to how appellate courts review evidence. The Court cited Ortiz v. Aramburo and Villanueva v. Estenzo to support this principle, emphasizing that practical considerations necessitate this practice and that the successor judge must base the decision entirely on the submitted records. On the alleged inconsistencies in prosecution testimonies, credibility of witnesses, and delay in giving statements: The Court found no actual contradiction between the testimonies of the medical expert and the eyewitnesses regarding the stab wound. The medical expert's testimony that there was no exit wound corroborated the eyewitnesses' accounts that the victim held the unembedded portion of the knife, preventing its full penetration. The testimonies regarding the manner of infliction (raising the weapon above the head and bringing it down) could result in a horizontal wound depending on the victim's position, and this did not contradict the medical findings. The small wound on the victim's body was also consistent with the victim holding onto the unembedded portion of the weapon. The Court reiterated the principle that the relationship of witnesses to the victim does not automatically render their testimony less credible, especially when there is no showing of improper motive. The fact that Socorro Garzon and Alejandro Gonzales, wife and driver of the deceased, respectively, did not immediately give their sworn statements was not deemed sufficient to discredit their clear and positive testimonies. Their natural interest in seeing the guilty convicted would deter them from implicating innocent parties. On the appreciation and evaluation of evidence, considering the flight of a co-accused: The Court noted that the flight of Uldarico Prado, a co-accused, might be indicative of his guilt but could not be used to exculpate the appellant, Gregorio Narajos, from liability. The actions of one co-accused do not automatically absolve another, especially when there is sufficient evidence pointing to the latter's culpability. The Court found no reversible error in the trial court's appreciation and evaluation of the evidence presented. The testimonies, when considered together and in light of the physical evidence, established the guilt of the accused beyond reasonable doubt. The alleged errors in the trial court's enumeration of exhibits were deemed mere inadvertences, as the judge did refer to other exhibits in his discussion, and all thirteen exhibits were submitted to him. On the conviction of the accused-appellant: The Court's decision to convict the accused-appellant was based on the totality of the evidence presented, including consistent testimonies, physical evidence, and the lack of reversible error in the trial court's appreciation and evaluation of said evidence.
Main Doctrine
A judge may validly render a decision although he has only partly heard the testimony of witnesses, provided that the decision is based entirely on the cold record before him, similar to how appellate courts review evidence.