G.R. No. 47747 February 15, 1990
TAN ANG BUN, petitioner, vs. COURT OF APPEALS and THE PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioner Tan Ang Bun was convicted by the trial court of Homicide, Serious Physical Injuries, and Damage to Property through Reckless Imprudence. The charges stemmed from a vehicular accident on August 26, 1973, in Gerona, Tarlac. The prosecution’s case relied heavily on the testimonies of four eyewitnesses—Jesus Centeno, Jose de los Reyes, Alfredo de Dios, and Pablo Bernabe—who testified that Tan Ang Bun was driving negligently, leading to a collision that caused a death, serious injuries, and property damage. The Court of Appeals affirmed the conviction with modifications to the awarded damages.
Following the appellate decision, Tan Ang Bun filed a motion for new trial based on the recantations of the same four prosecution eyewitnesses. In their sworn affidavits, these witnesses disavowed their trial court testimonies, asserting that material portions were incorrect due to errors in transcription, translation, or omission. They now claimed that the petitioner was driving on his proper lane at a slow speed and was not overtaking at the time of the accident, thereby exonerating him from fault. Additionally, the complaining witness, Alfonso Go Ching Kae, executed an affidavit absolving the petitioner of any liability and waiving all claims.

ISSUE

Whether the recantations of the prosecution’s eyewitnesses warrant the acquittal of the petitioner.

RULING

Yes. The Supreme Court granted the petition, reversed the appellate court’s decision, and acquitted Tan Ang Bun. The Court emphasized that while recantations are generally viewed with suspicion as they can easily be obtained, they may be given weight under exceptional circumstances where they convincingly nullify the original testimony and cast serious doubt on the guilt of the accused. In this case, the recantations were executed by all four key prosecution eyewitnesses, were corroborative of each other in exculpating the petitioner, and were supported by the affidavit of the injured party waiving all claims. These circumstances created a compelling scenario where the very foundation of the conviction—the eyewitness accounts—was thoroughly dismantled. The Court found that the collective and consistent nature of the recantations, which directly impugned the factual basis for finding negligence, created reasonable doubt that could not be ignored. The Solicitor General’s concurrence with the petition further bolstered this conclusion. Consequently, the evidence of guilt was no longer sufficient to sustain a conviction beyond reasonable doubt, necessitating acquittal.