In People of the Philippines vs. Dionesio Santiago, the Supreme Court affirmed the conviction of Dionesio Santiago for double murder, emphasizing that voice identification is admissible evidence when the witness is familiar with the accused’s voice. The Court found that sufficient circumstantial evidence, including voice identification, established Santiago’s guilt beyond reasonable doubt, despite the absence of a direct eyewitness for one of the murders. The decision underscores the importance of credible witness testimony and the probative value of circumstantial evidence in criminal prosecutions, particularly when direct evidence is lacking.

A Midnight Pleading: Can a Voice Seal a Murder Conviction?

The case revolves around the tragic deaths of Igmedio Carigay and Myrna Samsona on December 31, 1993. Dionesio Santiago was accused of their murders. Central to the prosecution’s case was the testimony of Bien Beloya, who claimed to have overheard Myrna pleading for her life and recognized Santiago’s voice threatening to kill them. This was coupled with Beloya’s eyewitness account of Santiago and others attacking Igmedio. The defense challenged the credibility of these testimonies, particularly the reliability of voice identification, and argued that the prosecution failed to prove guilt beyond a reasonable doubt.

Building on this narrative, the Regional Trial Court of Antique convicted Santiago of double murder, relying heavily on Beloya’s testimony and circumstantial evidence. The court sentenced him to reclusion perpetua for each count. Santiago appealed, questioning the lower court’s reliance on voice identification and the lack of direct evidence for Myrna’s murder.

The Supreme Court, in affirming the conviction, addressed the admissibility and weight of voice identification as evidence. The Court referenced People vs. Reynaldo, noting that voice identification is acceptable when the witness and the accused have known each other for a considerable time. The key factor is the witness’s familiarity with the accused’s voice. Since Beloya testified that he knew Santiago well and could recognize his voice, the Court found this identification credible.

Furthermore, the Court considered the prosecution’s use of circumstantial evidence to prove Santiago’s involvement in Myrna’s murder. As direct evidence was lacking for Myrna’s death, the prosecution relied on several circumstances. One of these factors included Beloya overhearing Myrna pleading for her life followed by Santiago’s threat to kill them. Also, the fact that Santiago and his companions were seen attacking Igmedio immediately after the threat. For circumstantial evidence to suffice, the Supreme Court emphasized that there must be more than one circumstance. All of these circumstances must be proven and lead to a conviction beyond a reasonable doubt.

The Court highlighted the significance of the autopsy reports, which indicated that both victims sustained multiple stab wounds inflicted by sharp-edged objects, suggesting the involvement of multiple assailants. The court stated the following:

From the autopsy report, there is no doubt that the plurality of assassins is in existence because the evident proof that the commission of the crime was participated by more than one person is the numerous wounds that differentiate from each other suffered by the victims indicate plurality of the assailants. The testimony of Bien Beloya in this regard is supported by the autopsy report of the doctor.

Building on the plurality of assassins, the Supreme Court addressed the aggravating circumstances of abuse of superior strength. This was used in both the murder of Igmedio and Myrna. It was the prosecution’s claim that Santiago and his companions, being armed, took advantage of their numerical and physical advantage against the unarmed victims.

In addition, the prosecution noted that an aggravating circumstance of dwelling was present. However, the Court recognized that while this may be true, dwelling was not alleged in the Information as an aggravating circumstance as required by Section 8, Rule 110 of the Revised Rules on Criminal Procedure, which reads:

Sec. 8. Designation of the offense. – The complaint or information shall state the designation of the offense given by the statute, aver the acts or omissions constituting the offense and specify its qualifying and aggravating circumstances. If there is no designation of the offense, reference shall be made to the section or subsection of the statute punishing it.

Though the court did acknowledge that Santiago was guilty of murder, the court could not use the dwelling. However, the Supreme Court decided to modify the civil liabilities, increasing them. Despite dwelling not being used, it allowed the award of exemplary damages since dwelling was apparent in the crime and hence, the heirs should be paid exemplary damages.

FAQs

What was the key issue in this case?	The primary issue was whether the prosecution presented sufficient evidence to convict Dionesio Santiago of double murder, particularly focusing on the admissibility and weight of voice identification evidence. Also, the role and importance of the prosecution’s use of circumstantial evidence to prove the incident beyond a reasonable doubt.
Is voice identification valid evidence in the Philippines?	Yes, voice identification is considered valid evidence in Philippine courts, especially when the witness is familiar with the accused’s voice over a considerable period. This familiarity is a key factor in determining the credibility and reliability of such evidence.
What is needed for a circumstantial evidence-based conviction?	For a conviction based on circumstantial evidence, there must be more than one circumstance, the facts from which the inferences are derived must be proven, and the combination of all circumstances must produce a conviction beyond a reasonable doubt. This evidence must also create a seamless chain leading to one reasonable conclusion that the defendant is guilty beyond all reasonable doubt.
What are civil indemnities?	Civil indemnities, sometimes also called actual damages, are awarded to the family for the quantifiable loss, such as funeral expenses or medical expenses, when the family member was killed. Moral damages are a compensation that a person must give for mental anguish resulting from the act. Lastly, exemplary damages are a way to punish people who have committed an egregious crime or error.
What were the penalties of the incident?	Due to the nature of the felony, Santiago was charged with the crime of murder and, with no mitigating circumstance in consideration, he was charged with reclusion perpetua. In addition to this charge, he was expected to pay the indemnities to the family in question.
What are aggravating circumstances in murder cases?	Aggravating circumstances are factors that increase the severity of a crime. In this case, abuse of superior strength was considered as Santiago and his companions, being armed, took advantage of their numerical and physical advantage against the unarmed victims
What must be alleged?	The Revised Rules on Criminal Procedure require aggravating circumstances to be stated clearly in the complaint. Though in the incident there was the idea of dwelling, since it was not properly claimed it could not be used against Santiago in court.

The Supreme Court’s decision in People vs. Dionesio Santiago reaffirms the validity and importance of voice identification and circumstantial evidence in criminal cases. The ruling clarifies that such evidence, when credible and aligned with legal requirements, can support a conviction even in the absence of direct eyewitness testimony. Also, it highlights the need for proper allegations to have more leverage.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People of the Philippines, Plaintiff-Appellee, vs. Dionesio Santiago, Accused-Appellant., G.R. No. 133445, February 27, 2003