G.R. No. L-69386; April 4, 1990
ARMANDO DE GUZMAN and MARIO PUA, petitioners, vs. INTERMEDIATE APPELLATE COURT and PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioners Armando de Guzman and Mario Pua, supervisors at Isuzu Specialist Sales, Inc., were convicted of Qualified Theft for allegedly conspiring with and inducing their subordinate, office boy Romeo Bonoy, to steal automotive spare parts valued at P418.20 from their employer in December 1978. Bonoy, who was discharged to become a state witness, testified that the petitioners threatened his job security to compel him to steal, and that they facilitated the theft by personally frisking him as he exited the premises, allowing him to smuggle out the parts. The stolen items were recovered from Bonoy’s residence in February 1979 after he confessed to the police, implicating the petitioners as masterminds.
Following his initial confession and the filing of charges, Bonoy was allegedly taken by the petitioners, forced to sign a recanting affidavit exculpating them, and held against his will. He later escaped and executed a third affidavit reaffirming his original accusations. The trial court and the Intermediate Appellate Court found Bonoy’s testimony credible and convicted the petitioners. They appealed to the Supreme Court, subsequently presenting a new affidavit from Bonoy dated September 12, 1984, which recanted his entire testimony and claimed he acted alone under pressure from the company president.

ISSUE

Whether the recantation of the sole state witness, Romeo Bonoy, constitutes a valid ground for a new trial that would overturn the petitioners’ conviction for Qualified Theft.

RULING

The Supreme Court denied the petition and affirmed the conviction. The Court held that a recantation is inherently unreliable and viewed with extreme suspicion, as it merely substitutes one sworn statement for another and can easily be procured through coercion or monetary consideration. The judicial logic emphasizes that retractions do not automatically nullify a prior testimony, especially when the original testimony was given in open court, subjected to cross-examination, and found credible by the trial judge. The trial court’s assessment of Bonoy’s original testimony as detailed, consistent, and corroborated by recovered evidence was accorded great weight.
The Court found the new affidavit unconvincing, as it contradicted Bonoy’s firm and lengthy court testimony. Granting a new trial based on such a recantation would set a dangerous precedent, allowing witnesses to undermine final judgments easily. The petitioners failed to prove that the recantation was of such a nature that, if presented earlier, it would probably change the verdict. The conviction was thus sustained, with the penalty and civil liability as modified by the appellate court. The decision underscores the principle that convictions rest on the strength of the prosecution’s evidence and the credibility determinations of the trial court, not on the vacillating statements of a recanting witness.