GR 1540; (April, 1905) (Digest)
G.R. No. 1540 : April 8, 1905
PARTIES:
Complainant-Appellee: The United States
Defendants-Appellants: Victor Ramos, et al.
Counsel: C. Casademunt for appellants; Office of the Solicitor-General Araneta for appellee.
FACTS:
The defendants, Victor Ramos et al., were convicted in the court below for the crime of assault upon Ruperto Evaristo, a government detective. The assault occurred at night near San Lazaro when Evaristo exited a dimly lit Chinese store and was attacked by three armed men. Evaristo did not know the defendants prior to the incident. Their arrest approximately two months later was prompted by a report from Evaristo’s cousin, who overheard Ramos remark that their assault victim had recovered. At trial, the prosecution’s case relied primarily on: (1) the testimony of Detective John W. Green regarding an alleged confession by Ramos, and (2) the identification made by the complaining witness, Evaristo. After judgment and the elevation of the case to the Supreme Court, the defendants filed a motion for new trial based on newly discovered evidence. This evidence consisted of affidavits stating that Evaristo, who had since been convicted of bribery and was imprisoned in Bilibid with the appellants, had recanted his testimony and stated that the appellants were not his assailants.
ISSUE:
Was the evidence presented during the trial sufficient to sustain the conviction of the defendants beyond reasonable doubt?
RULING:
No. The Supreme Court REVERSED the judgment of the lower court and ACQUITTED the defendants.
The Court held that the evidence on record was insufficient for conviction. First, the testimony of Detective Green regarding Ramos’s alleged confession was inadmissible as it violated Section 4 of Act No. 619 (the law requiring confessions to be made before specified officials). Second, the Court found the identification by the complaining witness, Evaristo, to be unreliable. The identification was deemed to be based not on a clear recollection from the poorly lit, sudden attack, but rather on the information provided by his cousin regarding Ramos’s subsequent conversation. The Court noted that the motion for a new trial based on Evaristo’s recantation, while potentially sufficient grounds on its own, did not need to be ruled upon because the original trial evidence was already inadequate to prove guilt beyond reasonable doubt. The acquittal is with costs de oficio*.