G.R. No. L-49044 October 12, 1983
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LAO WAN SING alias CO TIOK alias WASING, defendant-appellant.

FACTS

Lao Wan Sing was convicted of arson by the Court of First Instance of Aklan and sentenced to reclusion perpetua. The conviction was affirmed by the Supreme Court in 1966. However, during the appeal’s pendency, two key prosecution witnesses, Guillermo Vidal and Jose Narce, executed affidavits recanting their trial testimonies. Based on these recantations, the Supreme Court granted a new trial in 1972, remanding the case solely to determine the truthfulness of the witnesses’ recantations. The lower court, in the new trial, was explicitly limited to evaluating the veracity of these recantations and could not re-examine other factual findings from the original trial that had been affirmed by the Supreme Court.
At the new trial, the defense presented the recanting witnesses, who testified that their original identification of the appellant was false and given under pressure or coaching. The prosecution presented rebuttal witnesses, including the original trial judge and others, to contest the recantations’ credibility. The lower court, after the limited new trial, found the recantations to be unreliable and reinstated the original conviction. Lao Wan Sing appealed this reinstatement.

ISSUE

The core issue is whether the recantations of prosecution witnesses Vidal and Narce are credible and truthful, thereby warranting the acquittal of the accused, or whether the original trial testimonies should prevail.

RULING

The Supreme Court affirmed the lower court’s judgment and upheld the conviction. The legal logic centers on the principle that recantations are exceedingly unreliable and viewed with suspicion. The Court emphasized that a retraction does not automatically nullify an original testimony given under oath. The evaluation hinges on which set of declarations carries the weight of truth. In this case, the Court found the original testimonies given during the trial to be more credible. The witnesses’ detailed and consistent accounts under cross-examination were deemed to represent the truth. Conversely, the recantations were deemed dubious, self-serving, and insufficiently supported by evidence. The Court noted the lack of corroboration for the witnesses’ claims of being coerced or coached during the original proceedings. Furthermore, the limited scope of the new trial, as defined by the Supreme Court’s 1972 Resolution, was properly observed; the lower court correctly confined itself to assessing the recantations’ veracity without revisiting other settled facts. Since the recantations were found untruthful, the original evidence of guilt stands. Therefore, the conviction for arson and the penalty of reclusion perpetua were sustained.