People v. Soria
REITERATIONFacts
The Antecedents: On April 7, 1992, in Solana, Cagayan, Romulo Soria y Galletes allegedly shot Patricio M. Reyes with a gun, inflicting fatal wounds. The information charged murder, alleging intent to kill, evident premeditation, and treachery. Procedural History: The case originated in the Municipal Circuit Trial Court (MCTC) and was forwarded to the Provincial Fiscal, who filed an information for murder. The accused pleaded not guilty. The prosecution presented witnesses Felix Bago, Aurea Reyes (mother of the victim), and Dr. Anastacia Taguba. The defense presented the accused and others. The Regional Trial Court (RTC) of Cagayan, Branch 2, found the accused guilty of murder and sentenced him to reclusion perpetua. The accused filed a motion for reconsideration and a motion for new trial based on affidavits of recantation from the victim's parents, which were denied. The accused appealed. The Petition: The accused appealed the RTC decision, assigning errors related to the denial of his motion for new trial, the conviction without considering the recantation affidavits, basing the conviction on an alleged extrajudicial confession (Exhibit C), and relying on prosecution witnesses instead of defense evidence.
Issue(s)
Whether the trial court erred in denying the motion for new trial based on the recantation affidavits and in convicting the accused despite the recantation affidavits of the victim's parents. Whether the trial court erred in basing its decision on Exhibit C, arguing it was an alleged extrajudicial confession. Whether the trial court erred in relying on prosecution witnesses instead of weighing defense evidence.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding the accused Romulo Soria y Galletes guilty beyond reasonable doubt of murder and sentencing him to reclusion perpetua. The Court dismissed the appeal for lack of merit.
Ratio Decidendi
On the denial of the motion for new trial and conviction despite recantation affidavits: The Court held that the motion for new trial was pro-forma, being a mere rehash of the motion for reconsideration. Furthermore, recantation of testimony, especially when procured by the defense counsel and made after conviction, is generally unreliable and viewed with disfavor. The affidavit of Ponciano Reyes, not being an eyewitness, was merely his personal opinion. The affidavit of Aurea Reyes, the eyewitness, was a recantation of her positive identification of the accused in open court. The trial court gave full credence to her testimony, noting her deportment and the circumstances of the identification (fluorescent lighting, close range, knowing the accused well). The Court emphasized that it is unnatural for a mother to falsely accuse someone of her son's death. Recanted testimony is exceedingly unreliable, and making solemn trials a mockery by allowing witnesses to change their minds is a dangerous precedent. The testimony given in court under oath, subject to cross-examination, and before an impartial judge is calculated to discourage falsehood. On Exhibit C being an extrajudicial confession: The Court clarified that Exhibit C was not an extrajudicial confession of the accused but the sworn statement of Aurea Reyes identifying the accused as the killer. The challenged decision was not based on any extrajudicial confession by the accused. On relying on prosecution witnesses over defense evidence: The Court reiterated that the trial court has the prerogative to assign value to the testimony of witnesses and its determination of credibility deserves the highest respect. The trial court has the advantage of observing the witnesses' deportment and manner of testifying. The accused failed to convince the Court that any exceptions to this principle, such as plain oversight or misapplication of facts, should be applied.
Main Doctrine
Recantation of testimony given in open court, especially when made after conviction and procured by the defense counsel, is generally unreliable and viewed with disfavor by the courts. The trial court's assessment of the credibility of witnesses, based on their deportment and manner of testifying, deserves high respect.