GR 217721; (September, 2021) (Digest)

FACTS

Petitioner Benjie Lagao y Garcia was charged with Homicide for allegedly attacking and striking Anthony Sumad-ong Nerida with a hard object on February 20, 2008, in Bauang, La Union, causing fatal injuries that led to the victim’s death on February 22, 2008. Upon arraignment, petitioner pleaded not guilty. The prosecution presented witnesses Ricardo de Guzman, Ryan Cruz, and the victim’s father, Alfredo Nerida, Sr. De Guzman and Cruz testified that on the evening of February 20, 2008, they saw the victim with a bleeding nose and a head wound. During a drinking session, the victim told them he had an altercation with the petitioner about being drunk at work, during which the petitioner boxed him, struck his nose, and hit him with a bottle on the back of his head. The victim refused to seek medical attention or report the incident. Nerida, Sr. corroborated that the victim identified the petitioner as the assailant and testified on funeral expenses. The defense presented the petitioner, who denied inflicting injuries, and Dr. Bernardo Parado, who conducted the autopsy. Dr. Parado testified that the cause of death was “cardio-respiratory arrest secondary to hypovolemic shock secondary to intracranial hemorrhage secondary to blunt force injury occipital area, middle,” contradicting the death certificate which listed respiratory failure and sepsis. The Regional Trial Court convicted petitioner of Homicide, sentencing him to imprisonment and ordering him to pay damages. The Court of Appeals affirmed the conviction, ruling the victim’s statements to witnesses were part of res gestae. Petitioner appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt, contending the witnesses’ testimonies were hearsay and inadmissible as res gestae or dying declaration.

ISSUE

Whether the Court of Appeals erred in affirming the judgment of conviction for Homicide despite the prosecution’s alleged failure to prove petitioner’s guilt beyond reasonable doubt.

RULING

The Supreme Court GRANTED the petition and REVERSED the decisions of the lower courts. The prosecution failed to prove petitioner’s guilt beyond reasonable doubt. The testimonies of prosecution witnesses De Guzman and Cruz, which were based solely on the victim’s out-of-court statements identifying the petitioner as the assailant, were inadmissible hearsay. The Court ruled these statements did not qualify as part of the res gestae because they were not spontaneous or made while the startling occurrence was taking place; the victim made the statements approximately two hours after the alleged altercation during a drinking session, allowing time for reflection. The statements also did not qualify as a dying declaration because there was no evidence the victim was under a consciousness of impending death when he made them; he refused medical treatment and did not manifest such awareness. The cause of death established by Dr. Parado’s autopsy (blunt force injury) was inconsistent with the cause stated in the death certificate (respiratory failure, sepsis, etc.), creating reasonable doubt. The petitioner’s denial, coupled with the weak and inadmissible evidence against him, warranted acquittal. The constitutional presumption of innocence must prevail when the prosecution’s evidence does not meet the required quantum of proof.