People v. Marquina
REITERATIONFacts
The Antecedents: On August 17, 1991, Enrico Gaon was found sprawled in an open canal in Pasig City, Metro Manila, with multiple stab wounds. He was still breathing when discovered by his common-law wife, Elisa Molina, and later attended to by his brother, Romel Gaon. Romel Gaon testified that before Enrico died, he identified Ramil Marquina as his assailant. A fan knife with bloodstains was recovered from the crime scene. The autopsy report by Dr. Emmanuel Aranas detailed 48 wounds, including several deep stab wounds to the neck that lacerated the trachea and left common carotid artery, and wounds to the lungs. Procedural History: The accused, Ramil Marquina, Diego Esguerra, and Ben Priela, were charged with Murder. The Regional Trial Court (RTC) acquitted Esguerra and Priela but convicted Marquina of Murder, sentencing him to reclusion perpetua and ordering him to indemnify the heirs of the victim. Marquina appealed the RTC decision. The Petition: The accused-appellant, Ramil Marquina, argued that the trial court erred in giving excessive weight and credence to the dying declaration of the deceased, contending that medical findings indicated it was impossible for the victim to speak clearly.
Issue(s)
Whether the trial court erred in giving excessive weight and credence to the alleged dying declaration of the deceased, considering the medical evidence regarding the victim's ability to speak clearly. Whether the totality of the evidence, including the alleged dying declaration, established the guilt of the accused-appellant beyond reasonable doubt.
Ruling
The Supreme Court reversed the decision of the Regional Trial Court, acquitting Ramil Marquina of the crime of murder due to reasonable doubt. The Court ordered his immediate release from custody unless lawfully held for another cause.
Ratio Decidendi
On the issue of the dying declaration and reasonable doubt: The Court held that the medical findings of Dr. Aranas, detailing the victim's severe neck injuries including a lacerated trachea, rendered it impossible for the victim to speak clearly. The autopsy report indicated that while the victim might produce sounds like moans or groans, the possibility of uttering legible, clear words was impossible. The Court emphasized that physical evidence, such as the medico-legal report, ranks higher in the hierarchy of trustworthy evidence than testimonial evidence when they contradict each other. The Court noted that the victim sustained multiple stab wounds on the neck, including those that lacerated the trachea and the left common carotid artery. Dr. Aranas testified that due to the accumulation of blood in the windpipe, the victim could only speak for a matter of seconds or a few minutes after the infliction of the wounds, and that this accumulation could occur in seconds. Considering the time elapsed from when the victim was found until Romel Gaon reached him, the Court doubted that the victim was able to clearly name his assailant. Therefore, the uncorroborated testimony of Romel Gaon regarding the dying declaration could not prevail over the physical evidence. On the issue of reasonable doubt: The prosecution failed to discharge the burden of proving the appellant's guilt beyond reasonable doubt, necessitating his acquittal on the ground of reasonable doubt. The Court found that the questionable admissibility and reliability of the alleged dying declaration, when weighed against the physical evidence and the lack of corroborating testimony, created reasonable doubt as to the appellant's guilt.
Main Doctrine
Where physical evidence, such as a medico-legal report detailing fatal neck injuries that would render speech impossible, directly contradicts the testimony of a witness regarding a dying declaration, the physical evidence must prevail. The prosecution must prove guilt beyond reasonable doubt, and if such doubt exists due to conflicting evidence, the accused must be acquitted.