G.R. No. 254747 . July 13, 2022.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ROD ANGELES Y MANLAPAZ @ “URO,” ACCUSED-APPELLANT.

FACTS

The case stemmed from the killing of Joey Puro Toong on July 15, 2009, in Quezon City. The prosecution’s primary witness, Philip Baltes, testified that he saw a group of seven to eight male teenagers, including accused-appellant Rod Angeles, attack and maul the victim. Baltes positively identified Angeles as the one who stabbed the victim in the chest with a double-edged knife during the assault. The victim later died from his injuries. The prosecution charged Angeles and several others with Murder, qualified by abuse of superior strength.
The defense interposed denial and alibi. Angeles claimed he was in Tarlac City at the time of the incident, having moved there after his marriage in 2008, and presented a barangay certification to support his residency. He asserted he was wrongfully arrested in 2010. Notably, in 2016, the prosecution witness Baltes recanted his initial testimony, claiming he never saw Angeles at the crime scene and that Angeles was innocent. The Regional Trial Court (RTC) convicted Angeles of Murder, sentencing him to reclusion perpetua, but acquitted his co-accused. The RTC gave no credence to Baltes’s recantation.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Rod Angeles for Murder based on the positive identification by a witness who later recanted his testimony.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court upheld the lower courts’ assessment giving full credence to Baltes’s original, positive identification of Angeles as the perpetrator and rejecting his subsequent recantation. The legal logic is anchored on the settled doctrine that a testimony given during trial under oath and subjected to cross-examination holds greater evidentiary weight than a later affidavit of recantation, which is inherently unreliable and viewed with suspicion. The Court emphasized that recantations are easily procured and can vacillate, making them insufficient grounds for overturning a final judgment. The trial court observed that during his recantation, Baltes appeared jittery and seemed to seek assistance, further undermining the credibility of his retraction.
The Court found that the prosecution successfully proved all elements of Murder. The qualifying circumstance of abuse of superior strength was correctly appreciated, as the attack by a group of seven to eight individuals against a single, unarmed victim clearly showed a deliberate use of force to ensure the crime’s commission without risk to themselves. Angeles’s defense of alibi was rightly rejected for being weak and unsubstantiated by clear and convincing evidence, especially in light of the positive identification. The penalty of reclusion perpetua was affirmed, with the Court ordering Angeles to pay civil indemnity, moral and exemplary damages, and interest to the victim’s heirs.