People v. Cruz
REITERATIONFacts
The Antecedents: The accused, Florentino Cruz, along with his son Francisco Cruz, was charged with the killing of Eugenio de la Cruz, who was married to Obdulia Angeles. The victim was allegedly shot multiple times, sustaining twenty wounds, several of which were mortal. Procedural History: The Court of Appeals convicted Florentino Cruz and imposed an indeterminate penalty of 8 years and 1 day of prison mayor to 14 years, 8 months, and 1 day of reclusion temporal, with an indemnity of P2,000, plus costs. The Petition: The accused appealed the decision of the Court of Appeals, arguing that the court erred in considering Exhibit B, an alleged ante mortem declaration of the deceased Eugenio de la Cruz, as sufficient proof of his guilt.
Issue(s)
Whether Exhibit B, an alleged ante mortem declaration, was sufficient proof of the accused's guilt. Whether the victim's belief of impending death was sufficiently established for the admissibility and weight of his declaration. Whether the delay between the declaration and the victim's death affected the validity of the declaration.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, finding the appeal to be without merit. The conviction of Florentino Cruz was upheld.
Ratio Decidendi
On the admissibility and weight of Exhibit B (ante mortem declaration): The Court held that the primary basis of the accused's appeal, which questioned the sufficiency of Exhibit B as proof of guilt, was without merit. The accused argued that the victim did not know the proximity and imminence of his death when he made the declaration. However, the Court found from the facts presented by the Court of Appeals that the deceased believed he was going to die, which was natural given that he was shot multiple times, described as "literally torn to pieces by bullets," and sustained twenty wounds, several of which were mortally inflicted. The Court emphasized that the value of an ante mortem declaration does not hinge on whether death immediately follows the statement, but on the declarant's state of mind, believing that death would result from the injuries. The victim's subsequent death from these wounds confirmed his belief that he was going to die. On the effect of the delay between the declaration and death: The Court clarified that the fact that the victim's death did not occur immediately after making his declaration, but twelve days later, did not necessarily prove that he did not expect to die or had hopes of recovery. The Court cited previous rulings (E.U. contra Mallari, E.U. contra Virrey, Pueblo contra Lara, Pueblo contra Silang Cruz) establishing that the immediate succession of death is not the essential factor for the validity of an ante mortem declaration. What is essential is that the declarant, at the time of making the declaration, is in such a state of mind that he believes he will die from his injuries, and this belief is subsequently realized, as it was in the case of Eugenio de la Cruz. The victim's death itself served as proof that his belief was not erroneous. On the sufficiency of other evidence: Prescinding from the ante mortem declaration (Exhibit B), the Court found that the records still offered sufficient proof to sustain the judgment of the Court of Appeals. This additional evidence came from the testimony of the victim's widow, who witnessed the entire incident from the beginning until the accused and his son turned against her. Her testimony corroborated all that the deceased had stated in his declaration.
Main Doctrine
The admissibility and weight of an ante mortem declaration do not depend on the immediate succession of death, but on the belief of the declarant that death is imminent at the time the declaration is made. The declarant's subsequent death from the injuries sustained corroborates this belief.