People vs. Soria

G.R. No. 119007 (October 4, 1996)

Facts:

The case involves the accused, Romulo Soria y Galletes, who was charged with the murder of Patricio M. Reyes on April 7, 1992, in Solana, Cagayan. The charge stemmed from an incident where Soria allegedly entered the house of Felix Bago, where the Reyes family was having dinner, and opened fire with a gun. Witnesses, including Aurea Reyes (the victim's mother) and Felix Bago, testified that Soria aimed at Felix but missed, subsequently hitting Patricio in the arm as he attempted to take cover. After failing to hit Felix, Soria returned to the house and shot Patricio, who was lying on the floor, resulting in multiple gunshot wounds that caused his death.

The prosecution's case was supported by the testimonies of Aurea Reyes, Felix Bago, and Dr. Anastacia Taguba, who conducted the autopsy. The defense presented an alibi, claiming that Soria was at the house of Leonardo Bago during the time of the shooting, where he was involved in butchering dogs for a gathering. The trial court found the prosecution's evidence credible, particularly the eyewitness account of Aurea Reyes, and rejected the alibi as unconvincing.

Legal Issues:

1. Whether the trial court erred in denying the motion for new trial based on newly discovered evidence.
2. Whether the trial court properly considered the testimonies of the witnesses and the evidence presented.
3. Whether the conviction was based solely on the extrajudicial confession of the accused.
4. Whether the trial court's assessment of the credibility of witnesses was appropriate.

Arguments:

• Prosecution: The prosecution argued that the evidence presented, particularly the eyewitness testimony of Aurea Reyes, was sufficient to establish the identity of the accused and the circumstances of the crime. They contended that the attack was premeditated and executed with treachery, as Soria returned to shoot Patricio after initially missing Felix.

• Defense: The defense contended that the trial court erred in not considering the affidavits of Aurea and Ponciano Reyes, which allegedly disowned the accusation against Soria. They argued that the trial court relied too heavily on the prosecution's witnesses and failed to give due weight to the defense's evidence, including the alibi. The defense also claimed that the conviction was based on an extrajudicial confession that was not properly substantiated.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding no merit in the appeal. It held that the trial court did not err in denying the motion for new trial, as the affidavits presented were merely rehashes of previous arguments and did not constitute newly discovered evidence. The court emphasized that the recantation of Aurea Reyes was suspect, especially since it was made after the conviction and was sworn before the defense counsel. The court reiterated that recantations are generally viewed with skepticism and should not be given probative value, particularly when they contradict prior sworn testimony given in court.

The court also upheld the trial court's assessment of the credibility of witnesses, noting that the trial court had the advantage of observing the demeanor and conduct of the witnesses during their testimonies. The court found that the trial court's conclusions regarding the presence of treachery in the commission of the crime were well-founded, as Soria's actions demonstrated a deliberate and sudden attack on an unsuspecting victim.

Significant Legal Principles Established:

1. Credibility of Witnesses: The trial court's determination of witness credibility is given great weight, as it has the opportunity to observe the witnesses firsthand.
2. Recantation of Testimony: Recantations are generally viewed with suspicion and are often considered unreliable, especially when made after a conviction.
3. Treachery in Murder: The presence of treachery can be established when the attack is sudden and unexpected, leaving the victim without a chance to defend themselves.