G.R. Nos. 138874-75. July 21, 2005.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. FRANCISCO JUAN LARRAÑAGA, et al., Accused-Appellants.

FACTS

This case involves consolidated motions for reconsideration filed by the accused-appellants, including Francisco Juan Larrañaga, Josman Aznar, Rowen Adlawan, Alberto Caño, Ariel Balansag, and brothers James Andrew Uy and James Anthony Uy. They were convicted by the Supreme Court in a Decision dated February 3, 2004, for the special complex crime of kidnapping and serious illegal detention with homicide and rape (Criminal Case No. CBU-45303) and for simple kidnapping and serious illegal detention (Criminal Case No. CBU-45304). The crimes stemmed from the abduction of sisters Marijoy and Jacqueline Chiong in Cebu on July 16, 1997. The appellants were sentenced to death or reclusion perpetua, depending on their participation and, in the case of James Anthony Uy, his minority at the time of the crime.
The appellants raised multiple grounds in their motions, including alleged errors in barring testimony from Larrañaga and an NBI director, claims of planted evidence, the sufficiency of alibi defenses, the prevention of key defense evidence, the identity of a recovered corpse, and the credibility of discharged state witness Davidson Valiente Rusia. Supplemental motions introduced an affidavit from NBI Regional Director Florencio Villarin criticizing the police investigation and a separate forensic study questioning the body identification.

ISSUE

Whether the Supreme Court’s Decision convicting the appellants should be reconsidered based on the alleged errors and newly presented evidence raised in the motions.

RULING

The Supreme Court En Banc denied all motions for reconsideration. The Court held that the motions essentially rehashed arguments already thoroughly considered and passed upon in the main Decision. The legal logic is that a motion for reconsideration must demonstrate that the decision contains errors of fact or law that warrant a reversal, not merely reiterate previously rejected points. The Court found no compelling reason to deviate from its findings.
Regarding the new evidence, the affidavit of Atty. Villarin and the forensic study were deemed inadmissible and insufficient to overturn the conviction. The affidavit constituted hearsay, as Villarin did not testify and could not be cross-examined, and it did not pertain to facts of which he had personal knowledge. The forensic study was similarly rejected as it was not presented during trial and its belated submission did not meet the criteria for newly discovered evidence. The positive identification of the appellants by credible witnesses, including the discharged state witness whose testimony was found credible and corroborated, along with the established chain of circumstantial evidence, overwhelmingly proved their guilt beyond reasonable doubt. The Court affirmed that the trial was conducted fairly, and all constitutional rights of the accused were respected. The penalties imposed, including the death penalty for the principal offenders, were upheld as proper under the law.