G.R. No. L-48656 December 21, 1987
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NORMAN AMPARADO, defendant-appellant.

FACTS

Accused-appellant Norman Amparado was convicted of Murder for the death of Manuel Maghanoy and sentenced to reclusion perpetua. His conviction was affirmed on appeal by the Supreme Court, which only modified the civil indemnity. Amparado subsequently filed a motion for a new trial based on newly discovered evidence, errors of law, and the interest of substantial justice. He specifically offered the testimonies of Antonio Cachin Jr. and Manuel Henry Auza, who claimed to be the first persons to assist the victim after the stabbing incident inside a house, contradicting the prosecution’s narrative.
The prosecution’s case heavily relied on the eyewitness account of Rogelio Patangan, who testified that the stabbing occurred treacherously on a road. In contrast, the defense maintained it happened inside a house in self-defense. In his affidavit, Amparado explained that despite reasonable diligence, he could not locate Cachin and Auza earlier because he avoided the crime scene area for years due to fear of retaliation from the victim’s relatives. He only discovered these witnesses after a chance encounter with a prosecution witness, Roseller Ladera, following the Supreme Court’s affirmance of his conviction.

ISSUE

Whether the motion for a new trial based on newly discovered evidence should be granted.

RULING

Yes, the motion for a new trial is granted. The Supreme Court held that the proposed testimonies of Antonio Cachin Jr. and Manuel Henry Auza constitute newly discovered evidence under Section 2(b), Rule 121 of the Rules of Court. The legal logic requires that such evidence: (1) was discovered after trial; (2) could not have been discovered and produced at the trial even with reasonable diligence; (3) is material, not merely cumulative, corroborative, or impeaching; and (4) is of such weight that it would probably change the judgment.
The Court found that Amparado exercised reasonable diligence but was legitimately prevented from discovering the witnesses earlier due to his well-founded fear for his safety, which kept him away from the locus of the crime. The evidence is material and not merely cumulative, as it directly attacks the credibility of the prosecution’s sole eyewitness, Rogelio Patangan, by alleging his absence from the scene. If proven, this would severely undermine the prosecution’s version of events occurring on the road and could substantiate the defense’s claim of a different locale (inside a house) and circumstance (self-defense), potentially altering the verdict from murder to a lesser offense or acquittal. Consequently, the Court set aside its prior affirmance and remanded the case to the trial court for a new trial to receive this new evidence.