G.R. No. L-55533. July 31, 1984.
PEOPLE OF THE PHILIPPINES, petitioner, vs. THE COURT OF APPEALS, JOSE V. PEREZ, AMADEA C. PEREZ, CIPRIANO LADINES and FLAVIA C. VALDENOR, respondents.

FACTS

The petitioner, the People of the Philippines, filed this petition to set aside the decision of the Court of Appeals which affirmed a trial court order. The order denied the prosecution’s motion to discharge accused Miguel Roncesvalles from an information for violation of the Agricultural Loan Law so he could testify as a state witness against his co-accused. The amended information charged Roncesvalles and the private respondents with conspiracy to make false statements in a loan application to secure a P30,000.00 loan from the Rural Bank of Lucena, Inc.
After the prosecution had presented seven witnesses, the state prosecutors filed a motion to discharge Roncesvalles. They alleged he met the requisites under the Rules: he was not the most guilty, his testimony was absolutely necessary and could be corroborated, no other direct evidence was available, and he had no prior conviction for moral turpitude. The trial court denied the motion, reasoning that Roncesvalles could not be considered the least guilty as he appeared to be a principal by direct participation. It also held that the prosecution’s presented witnesses did not show how his testimony would be corroborated.

ISSUE

Whether the Court of Appeals acted with grave abuse of discretion in sustaining the trial court’s denial of the motion to discharge accused Miguel Roncesvalles as a state witness.

RULING

Yes. The Supreme Court granted the petition and set aside the appellate court’s decision. The legal logic centers on the proper interpretation and application of Section 9, Rule 119 of the Rules of Court, which governs the discharge of an accused to become a state witness. The trial court manifestly erred in its ruling. The rule requires that the accused sought to be discharged “does not appear to be the most guilty.” It does not require that he be the “least guilty.” The trial court’s own acknowledgment that Roncesvalles was a principal or co-principal does not equate to him being the most guilty among the accused. The law permits the discharge of a participant in the crime, as a candid admission of guilt can be a guarantee of truthful testimony.
Furthermore, the Court emphasized that the discretion granted to trial courts in evaluating such motions is not arbitrary but must be exercised judiciously to serve the proper administration of justice. The prosecution’s assertion of absolute necessity, made after presenting seven witnesses, was a timely demonstration under prevailing jurisprudence that such a motion is best evaluated after the prosecution has presented its other evidence. The greater purpose of the rule is to prevent crimes from going unpunished by securing the conviction of the more guilty through the testimony of a co-accused. Therefore, the orders were reversed, and the trial court was directed to allow the discharge of Roncesvalles as a state witness.