Guzman v. People
REITERATIONFacts
The Antecedents: Armando de Guzman and Mario Pua, employees of Isuzu Specialist Sales, Inc., were accused of Qualified Theft for allegedly instructing Romeo Bonoy, a co-employee, to steal automotive spare parts valued at P418.20. Bonoy, an eighteen-year-old office and delivery boy, testified that the petitioners threatened him to cooperate in stealing the parts and that they were responsible for frisking employees as they left the premises, facilitating the undetected removal of the stolen items. The stolen parts were recovered from Bonoy's residence. Procedural History: Initially charged in an amended Information dated March 21, 1979, before the Court of First Instance (CFI) of Rizal, petitioners pleaded not guilty. Their co-accused, Romeo Bonoy, was discharged to become a state witness. The CFI convicted both petitioners of Qualified Theft, sentencing them to an indeterminate penalty. On appeal, the Intermediate Appellate Court (IAC) affirmed the conviction with modification regarding the indemnity. Petitioners sought reconsideration, which was denied. They then filed a supplemental motion for reconsideration based on an alleged recantation by Bonoy, which the IAC also denied, deeming it a second motion for reconsideration and not newly-discovered evidence. Petitioners then filed a petition for review with the Supreme Court, which was initially denied but later given due course. The Petition: Petitioners seek reversal of the IAC decision, primarily arguing that the testimony of the sole prosecution witness, Romeo Bonoy, which was later repudiated by an affidavit of recantation, is insufficient to establish guilt beyond reasonable doubt. They contend that the IAC gravely abused its discretion in denying their motion for new trial based on this recantation. The issues raised include the evidentiary weight of a retracted testimony, the propriety of denying a motion for new trial based on recantation, the alleged denial of due process due to lack of notice to counsel, and the overall abuse of discretion in light of the recantation. Petitioners ultimately pray for outright acquittal.
Issue(s)
Whether the testimony of the lone prosecution witness, subsequently repudiated in an affidavit of recantation, constitutes proof beyond reasonable doubt to sustain conviction. Whether the respondent court acted with grave abuse of discretion in denying petitioners' motion for new trial based on the witness's recantation. Whether the failure to notify the counsel on record is a fatal defect amounting to a denial of due process. Whether the outright denial of the motion for new trial constitutes gross abuse in light of the recantation; and overall assessment of evidence.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Intermediate Appellate Court. The Court held that the recantation of testimony is generally viewed with disfavor and is not a ground for new trial unless there is no other evidence to sustain the conviction. The Court found Bonoy's testimony credible and consistent, corroborated by the circumstances of the case, and sufficient for conviction. The Court also found that the affidavit of recantation was not newly-discovered evidence and that the denial of the motion for new trial was not tainted with grave abuse of discretion.
Ratio Decidendi
On the issue of recantation of testimony and sufficiency of Bonoy's testimony: The Court reiterated its disfavor towards recantations of testimony previously given in court, viewing them with suspicion. It emphasized that affidavits of retraction are exceedingly unreliable and require careful examination. The Court found Bonoy's testimony sufficient for conviction, even without corroboration, highlighting its consistency and the corroborating circumstances of the case. The Court reiterated the principle that witnesses are weighed, not numbered, and the testimony of a single credible witness is sufficient for conviction. On the denial of the motion for new trial: The Court agreed with the Solicitor General that the affidavit of recantation was not newly-discovered evidence. Furthermore, the supplemental motion for reconsideration, which included the recantation, was considered a second motion for reconsideration, which is generally not allowed. The Court found no error in the appellate court's refusal to characterize the affidavit as newly-discovered evidence, as doing so would lead to endless litigation. The Court concluded that the appellate court did not commit grave abuse of discretion in denying the motion for new trial. On the issue of due process: While the issue of failure to notify counsel was raised, the Court did not extensively discuss it in the main ponencia, focusing instead on the substantive issues of recantation and sufficiency of evidence. However, the denial of the motion for new trial and the affirmation of the conviction implicitly suggest that the Court found no fatal defect amounting to a denial of due process in the proceedings. On the outright denial of the motion for new trial and overall assessment of evidence: The Court meticulously reviewed the records and evidence, finding itself persuaded that Bonoy's testimony in court deserved credence and was sufficient for conviction. The Court noted the striking consistency of Bonoy's testimony, which convinced the trial and appellate courts, and now the Supreme Court, of its truthfulness. The claim that petitioners were framed was previously considered and rejected as incredible.
Main Doctrine
The recantation of testimony previously given in court is viewed with disfavor and is generally considered unreliable, especially when executed years after the testimony and after the affirmation of the conviction, and when the circumstances surrounding the recantation are dubious. The court will carefully scrutinize such recantations, comparing them with the original testimony and considering the motives for the change. The testimony of a single credible witness, even if uncorroborated by other witnesses, is sufficient for conviction if it satisfies the court beyond reasonable doubt, especially when corroborated by the circumstances of the case.