G.R. No. 79570 . January 31, 1989.
GASPAR MEDIOS, petitioner, vs. THE HONORABLE COURT OF APPEALS AND THE PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioner Captain Gaspar Medios was charged with Direct Assault with Double Murder for the shooting deaths of PC Captain Guillermo Viloria and Engineer Celestino Egipto on May 12, 1979, in Roxas, Isabela. The prosecution’s evidence established that Captain Viloria, while on patrol, entered a compound where a birthday celebration was being held. He ordered the cessation of card games he believed to be illegal gambling. As the guests dispersed, a burst of automatic gunfire emanated from the doorway of the house, hitting both Viloria and Egipto. The prosecution’s eyewitness, Sgt. Patrio Amoroso, testified that after the initial burst, Medios approached the fallen Viloria, took the Captain’s M-16 rifle, and shot him twice more.
The trial court convicted Medios not of the complex crime charged, but of two separate crimes of Homicide. It rejected the qualifying circumstances of treachery and the allegation that Viloria was attacked in the performance of his official duties. The Court of Appeals affirmed the conviction. Medios appealed to the Supreme Court, challenging the credibility of the prosecution’s eyewitness and the admissibility of the victims’ ante-mortem statements.

ISSUE

The core issues were: (1) whether the trial and appellate courts erred in giving credence to the testimony of prosecution witness Patrio Amoroso; and (2) whether the courts erred in admitting the victims’ statements identifying Medios as the assailant.

RULING

The Supreme Court affirmed the conviction. On the first issue, the Court upheld the factual findings of the lower courts, emphasizing that the assessment of witness credibility is best undertaken by the trial judge who observes the witness’s demeanor and manner of testifying. The Court found no compelling reason to deviate from the trial court’s conclusion that Amoroso’s testimony was credible and consistent. The defense’s theory of frame-up was deemed unconvincing.
On the second issue, the Court ruled that the victims’ statements were properly admitted as part of the res gestae. The statements, made to investigators and a doctor shortly after the shooting, were given under the influence of a startling event and before the declarants had time to contrive a falsehood. While a written statement signed by Captain Viloria was inadmissible due to the prosecution’s failure to prove he read it or had its contents read to him, the oral testimony of the witnesses who heard the victims’ declarations was admissible. The Court clarified that for a statement to qualify as part of the res gestae, it need only be made under the stress of a startling occurrence and relate to its circumstances, which the victims’ identifications of Medios satisfied. Therefore, the evidence sufficiently established Medios’s guilt for two counts of Homicide beyond reasonable doubt.