G.R. No. L-36094 July 16, 1982
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANASTACIO DELASA, defendant-appellant.

FACTS

Anastacio Delasa was convicted by the Court of First Instance of Leyte for the crime of Robbery with Homicide and sentenced to reclusion perpetua. The prosecution evidence established that on September 26, 1972, the victim, Anselmo Pondoyo, was harvesting rice with his wife Virona and son Alberto. While returning home, Anselmo went ahead and was seen conversing with the appellant and another man. While crossing an improvised bridge, Delasa stabbed Anselmo twice in the back with a bolo, fatally wounding him. The appellant then slashed the victim’s pants, took P500.00 from his pocket, and fled with his companion.
During the pendency of his appeal, Delasa filed a motion for new trial based on newly discovered evidence. This consisted of affidavits of recantation executed by the principal eyewitnesses, Virona and Alberto Pondoyo, who now claimed they did not actually witness the crime. The motion also included a statement from an alleged eyewitness, Inocencio Damayo, who pointed to different individuals as the perpetrators.

ISSUE

The core issue is whether the motion for new trial based on the recantations of the eyewitnesses and the new witness statement should be granted, warranting a reversal of the conviction.

RULING

The Supreme Court denied the motion for new trial and affirmed the conviction. The legal logic rests on the stringent requirements for granting a new trial based on newly discovered evidence and the infirmity of recanted testimony. For newly discovered evidence to merit a new trial, it must be shown that such evidence could not have been discovered and produced at the trial despite the exercise of reasonable diligence. The Court found no such showing regarding the alleged eyewitness Inocencio Damayo; his testimony did not qualify as newly discovered evidence.
Regarding the recantations, the Court ruled they must be viewed with extreme caution. The original testimonies of Virona and Alberto were given in open court under oath, subject to cross-examination, and under the observant eye of the trial judge who assessed their credibility. The rule disfavoring recantations is grounded in public policy, as granting new trials based solely on post-conviction retractions would lead to endless litigation and allow interested parties to subvert justice by coercing or inducing witnesses to change their stories. The positive identification of the appellant by two credible eyewitnesses, who were his neighbors and had no improper motive to testify falsely, prevailed over his weak defense of alibi, especially given the proximity of his claimed location to the crime scene. The trial court’s findings on witness credibility are thus sustained.