GR L 15256; (October, 1963) (Digest)
G.R. Nos. L-15256-57; October 31, 1963
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PASCUAL CURIANO, ET AL., defendants-appellants.
FACTS
The appellants were convicted by the Court of First Instance of Samar for the crimes of murder and multiple murder for the killings of Rafael Yboa, Daniel Errabo, Engracia Salazar, and Mario Errabo. The trial court found the presence of multiple aggravating circumstances and imposed the death penalty. Pending appeal, the appellants filed a motion for a new trial based on newly-discovered evidence, consisting primarily of affidavits. The key affidavit was from appellant Hermenegildo Tafalla, who claimed that only he and three other individuals not on trial were the actual perpetrators. This was corroborated by affidavits from several other persons, including relatives of the accused.
ISSUE
Whether the motion for a new trial based on the submitted affidavits should be granted.
RULING
The Supreme Court denied the motion for a new trial and affirmed the convictions, albeit modifying the penalty. The legal logic for denying the new trial is multi-faceted. First, the Court found Hermenegildo Tafalla’s affidavit to be a last-ditch, self-serving attempt to exculpate his co-accused, particularly his brothers, and to implicate individuals who were at large and unavailable for trial. Second, the evidence was not considered “newly-discovered” as the information within the affidavits was allegedly known to some affiants as early as a month after the crime but was not presented during the trial. Third, the affidavits constituted mere retractions or impeachment of the original trial evidence. Established jurisprudence holds that such evidence does not warrant a new trial unless the conviction rested solely on the testimony of the now-retracting witness, which was not the case here. The Court emphasized the danger of granting new trials based on post-conviction affidavits, as it would lead to interminable litigation. On the merits, the Court upheld the findings of treachery and abuse of superior strength. It corrected the trial court’s appreciation of aggravating circumstances, disregarding cruelty and lack of provocation. Due to the lack of the necessary votes for execution, the death sentences were commuted to life imprisonment for each of the four murders, with indemnities increased.