G.R. No. 136258; October 10, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CARLOS FELICIANO, accused-appellant.

FACTS

Accused-appellant Carlos Feliciano and Rodel de la Cruz were security guards assigned at the Kingsmen building in Kalibo, Aklan. They were jointly charged with Robbery with Homicide for the killing of Teresita Fuentes in the early morning of June 5, 1995. The victim was brutally bludgeoned, and cash and jewelry were taken from her. The prosecution filed a motion to discharge de la Cruz to be a state witness against Feliciano. Over the defense’s strong objection, the trial court granted the motion. De la Cruz then testified that Feliciano was the principal assailant, narrating that Feliciano robbed and killed the victim using a .38 caliber revolver as a bludgeon, and that he (de la Cruz) merely assisted under duress. The trial court convicted Feliciano and imposed the death penalty.

ISSUE

Whether the trial court erred in discharging accused Rodel de la Cruz to be a state witness against appellant Carlos Feliciano.

RULING

The Supreme Court affirmed the conviction but reduced the penalty to reclusion perpetua. It held that the discharge of de la Cruz was proper under Section 9, Rule 119 of the Rules of Court. The requisites for a valid discharge are: (a) absolute necessity for the testimony of the accused whose discharge is requested; (b) no other direct evidence available for the proper prosecution of the offense; (c) the testimony of said accused can be substantially corroborated; (d) said accused does not appear to be the most guilty; and (e) said accused has not at any time been convicted of any offense involving moral turpitude. The Court found these conditions satisfied. De la Cruz’s testimony was indispensable as there were no other eyewitnesses, and his account was corroborated by physical evidence and the recovery of stolen items. He was not the most guilty, as his participation was limited to assisting Feliciano under compulsion. The Court emphasized that the state witness rule, while seemingly rewarding treachery, is a necessary tool for the state to uncover and prosecute crimes that would otherwise remain concealed. Feliciano’s defenses of denial and alibi were deemed weak and unsubstantiated. However, the Court found that the aggravating circumstances alleged were not proven beyond reasonable doubt, warranting the reduction of the penalty from death to reclusion perpetua.