G.R. No. 142654 ; November 16, 2001
PEOPLE OF THE PHILIPPINES, appellee, vs. ROLANDO MENDOZA y CARPIO, appellant.

FACTS

On October 11, 1998, in Caloocan City, Prudencio Valdoz was repeatedly stabbed by Rolando Mendoza and Reynaldo Balverde. Eyewitness Eduardo Mariquit saw the attack and later assisted the wounded victim. The victim was brought to the East Avenue Medical Center. While in the operating room, in great pain, Valdoz told Estrellita Carmelo that he might die and identified Mendoza and Balverde as his assailants. The following day, PO3 Alex Barroga took the victim’s ante mortem statement, where Valdoz, gasping for breath, again identified the appellant and his co-accused. Valdoz died on October 19, 1998.
Appellant Rolando Mendoza was charged with murder. During trial, he denied involvement, claiming he was elsewhere at the time of the incident. The prosecution presented the eyewitness account of Mariquit and, crucially, the dying declaration of the victim relayed by Carmelo and formalized in the ante mortem statement. The Regional Trial Court convicted Mendoza of murder and sentenced him to reclusion perpetua, prompting this appeal.

ISSUE

The core issue is whether the trial court erred in convicting the appellant based on the evidence presented, particularly the admissibility and sufficiency of the victim’s dying declaration.

RULING

The Supreme Court affirmed the conviction. The Court meticulously upheld the admissibility of the dying declaration as an exception to the hearsay rule, founded on necessity and trustworthiness. Necessity exists because the declarant is dead and cannot testify. Trustworthiness is established as the declaration was made under the consciousness of impending death, a solemn situation where the mind is presumed to be free from motives for falsehood. The declaration, made to Carmelo in the hospital and later to the police officer, met all legal requisites: it concerned the cause and circumstances of the declarant’s death, was made under the consciousness of impending death, and the declarant was competent to testify had he survived.
The Court found the dying declaration credible and corroborated by the eyewitness testimony of Mariquit. Appellant’s defense of alibi was weak and could not prevail over the positive identification. The declaration provided direct evidence of the appellant’s participation. The confluence of the dying declaration and the eyewitness account established Mendoza’s guilt beyond reasonable doubt. The Court thus sustained the penalty of reclusion perpetua and the awarded damages, affirming the trial court’s decision in toto.