G.R. No. 145336 ; February 20, 2013
REYNANTE TADEJA, RICKY TADEJA, RICARDO TADEJA and FERDINAND TADEJA, Petitioners, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioners Reynante, Ricky, Ricardo, and Ferdinand Tadeja, along with their cousin Plaridel Tadeja, were convicted of homicide for the killing of Ruben Bernardo during a barangay fiesta in 1994. The prosecution’s eyewitnesses, relatives of the victim, testified they saw the Tadeja brothers and Plaridel hack Ruben to death. The petitioners claimed self-defense, alleging Ruben and his sons attacked Reynante first. The Regional Trial Court found them guilty, a decision affirmed by the Court of Appeals. The Supreme Court subsequently denied their appeal, and the judgment became final and executory in July 2007.
Years later, petitioners filed an Urgent Motion to Reopen the case based on newly discovered evidence: an extrajudicial confession executed by their previously absconding co-accused, Plaridel Tadeja, after his apprehension in 2006. In this confession, Plaridel exonerated the petitioners, claiming he alone killed Ruben Bernardo in a separate incident later that night, and that the petitioners were not present. The Office of the Solicitor General did not object to the reopening.

ISSUE

Whether the case may be reopened for the reception of Plaridel Tadeja’s extrajudicial confession as newly discovered evidence after the judgment of conviction had attained finality.

RULING

The Supreme Court denied the motion to reopen. The legal logic is anchored on the doctrine of finality of judgment and the stringent requirements for a petition for relief from a final judgment. A judgment that has become final and executory is immutable and unalterable. Exceptions to this rule are extremely limited and require, among other criteria, that the newly discovered evidence be of such weight that it would probably change the judgment. The Court found Plaridel’s confession did not meet this standard. It was deemed inherently unreliable, being an extrajudicial confession of a co-accused taken long after the trial. Such a confession is hearsay against the petitioners and lacks corroboration. Furthermore, it was inconsistent with the physical evidence and the credible, consistent testimonies of eyewitnesses upon which the conviction was based. The Court emphasized that finality of judgments is a fundamental principle intended to end litigation. While the OSG did not object, the Court is not bound by such agreement when the evidence proffered is insufficient to warrant the extraordinary remedy of reopening a long-final conviction. The proper recourse for the petitioners, given the circumstances, is to seek executive clemency.