This case has been cited 4 times or more.
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2015-09-09 |
LEONARDO-DE CASTRO, J. |
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| Moreover, accused-appellant's verbal confession that he stabbed his father to death made to PO1 Torre and PO1 Macusi, established through the testimonies of said police officers, falls under Rule 130, Section 26 of the Rules of Court, which provides that "[t]he act, declaration or omission of a party as to a relevant fact may be given in evidence against him." This rule is based upon the notion that no man would make any declaration against himself, unless it is true.[18] Accused-appellant's declaration is admissible for being part of the res gestae. A declaration is deemed part of the res gestae and admissible in evidence as an exception to the hearsay rule when these three requisites concur: (1) the principal act, the res gestae, is a startling occurrence; (2) the statements were made before the declarant had time to contrive or devise; and (3) the statements concern the occurrence in question and its immediately attending circumstances.[19] All the requisites are present in this case. Accused-appellant had just been through a startling and gruesome occurrence, that is, his father's death. Accused-appellant made the confession to PO1 Torre and PO1 Macusi only a few minutes after and while he was still under the influence of said startling occurrence, before he had the opportunity to concoct or contrive a story. In fact, accused-appellant seemed to still be in shock when he walked to the Police Station completely unmindful of the rain and the knife in his hand, and headed directly to PO1 Torre and PO1 Macusi, who were standing in front of the Police Station, to confess to stabbing his father to death. The police officers who immediately went to the house of Jose, accused-appellant's father, found Jose's lifeless body with blood still oozing from his stab wounds. As res gestae, accused-appellant's spontaneous statement is admissible in evidence against him. | |||||
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2015-07-01 |
MENDOZA, J. |
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| While it is established that nothing less than proof beyond reasonable doubt is required for a conviction, this exacting standard does not preclude resort to circumstantial evidence when direct evidence is not available. Direct evidence is not a condition sine qua non to prove the guilt of an accused beyond reasonable doubt. For in the absence of direct evidence, the prosecution may resort to adducing circumstantial evidence to discharge its burden. Crimes are usually committed in secret and under conditions where concealment is highly probable. If direct evidence is insisted on under all circumstances, the prosecution of vicious felons who commit heinous crimes in secret or secluded places will be hard, if not impossible, to prove.[109] | |||||
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2015-06-29 |
VILLARAMA, JR., J. |
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| In this case, nobody witnessed the actual rape and killing of AAA. Appellant, however, may still be proven as the culprit despite the absence of eyewitnesses. Direct evidence is not a condition sine qua non to prove the guilt of an accused beyond reasonable doubt. For in the absence of direct evidence, the prosecution may resort to adducing circumstantial evidence to discharge its burden.[21] As we held in People v. Pascual[22]:It is settled that in the special complex crime of rape with homicide, both the rape and the homicide must be established beyond reasonable doubt. In this regard, we have held that the crime of rape is difficult to prove because it is generally unwitnessed and very often only the victim is left to testify for herself. It becomes even more difficult when the complex crime of rape with homicide is committed because the victim could no longer testify. Thus, in crimes of rape with homicide, as here, resort to circumstantial evidence is usually unavoidable.[23] | |||||
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2013-06-19 |
SERENO, C.J. |
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| However, in line with current jurisprudence, we modify the awards for civil indemnity and exemplary damages. Civil indemnity shall be increased to P100,000.00.[22] We also increase the award of moral damages to P75,000.00.[23] Lastly, respecting exemplary damages we decrease the same to P30,000.00.[24] | |||||