PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. P/SUPT. ARTEMIO E. LAMSEN, PO2 ANTHONY D. ABULENCIA, and SPO1 WILFREDO L. RAMOS, Accused-Appellants.
FACTS
This is a Resolution on Motions for Reconsideration and a Motion for New Trial filed by the accused-appellants, who were convicted of the crime of robbery with homicide. The Court’s Resolution dated February 20, 2013, upheld their conviction and sentenced them to reclusion perpetua, with corresponding civil liabilities. In their Motions, accused-appellants presented newly obtained affidavits from two prosecution witnesses, Amel F. Reyes and Domingo Marcelo. In these affidavits, Reyes and Marcelo recanted their trial testimonies, claiming they were forced by elements of the PNP, NBI, and a former mayor to falsely implicate the accused-appellants. They asserted they did not actually witness the crime and testified out of fear.
ISSUE
Whether the affidavits of recantation executed by prosecution witnesses Reyes and Marcelo constitute valid grounds for granting a new trial or reconsideration of the conviction.
RULING
The Supreme Court DENIED the Motions and AFFIRMED its February 20, 2013 Resolution. The Court held that affidavits of recantation are viewed with extreme suspicion and disfavor. Recantations are considered unreliable and dangerous, as they can easily be secured through intimidation or monetary consideration, and they make a mockery of solemn court proceedings. The test for evaluating a retraction is a careful comparison of the original and subsequent testimonies, scrutinizing the circumstances and motives for the change. The Court found no special circumstances in this case to justify upholding the recantations. The original testimonies of Reyes and Marcelo, along with other prosecution witnesses, were deemed credible by the trial court-described as candid, straightforward, categorical, and having withstood rigorous cross-examination. Furthermore, the recantations were executed only after the Court’s conviction had been rendered, more than a decade after the original testimonies, appearing as a last-minute attempt to evade punishment. The other issues raised in the Motions were deemed already exhaustively passed upon in the earlier Resolution.
