In the Philippines, a conviction for a crime requires proof beyond a reasonable doubt. This means the prosecution must present enough credible evidence to convince the court that the accused is guilty. In Benjie Lagao y Garcia v. People of the Philippines, the Supreme Court acquitted the accused of homicide, highlighting the critical importance of admissible evidence and the burden of proof in criminal cases. The Court emphasized that testimonies based on hearsay, or statements not directly observed by the witness, are generally inadmissible and cannot form the basis of a conviction unless they fall under specific exceptions like dying declarations or res gestae. This ruling underscores the judiciary’s commitment to protecting the constitutional right to presumption of innocence and ensuring that convictions are based on solid, reliable evidence.

Can Secondhand Stories Convict? Evaluating Hearsay in a Homicide Trial

Benjie Lagao was accused of homicide for allegedly inflicting fatal injuries on Anthony Sumad-ong Nerida. The prosecution’s case hinged on the testimonies of witnesses who claimed the victim told them that Lagao had assaulted him. However, there were no eyewitnesses to the alleged crime. The Regional Trial Court (RTC) convicted Lagao, and the Court of Appeals (CA) affirmed, both relying heavily on the victim’s statements as recounted by the witnesses. The Supreme Court (SC) reversed these decisions, acquitting Lagao due to the inadmissibility of the hearsay evidence and the presence of reasonable doubt regarding the cause of the victim’s death.

The Supreme Court’s decision hinged on whether the testimonies of the prosecution witnesses were admissible as exceptions to the hearsay rule. Hearsay evidence is defined as statements offered in court to prove the truth of the matter asserted, which are not based on the personal knowledge of the witness. Such evidence is generally inadmissible because the declarant (the person who made the statement) is not under oath and cannot be cross-examined to verify the truthfulness of the statement. The Rules of Evidence provide exceptions to this rule, including dying declarations and statements forming part of res gestae.

A dying declaration is an exception where a statement made by a person about the cause and circumstances of their impending death is admissible, provided the declarant believed death was imminent at the time of making the statement. The Court emphasized that for a statement to qualify as a dying declaration, the declarant must have a consciousness of impending death. As the Supreme Court stated,

Verily, because the declaration was made in extremity, when the party is at the point of death and when every motive of falsehood is silenced and the mind is induced by the most powerful considerations to speak the truth, the law deems this as a situation so solemn and awful as creating an obligation equal to that which is imposed by an oath administered in court.

In this case, the victim’s actions and statements did not reflect a belief that death was imminent. The Court noted that the victim continued to drink and socialize after the alleged assault and did not immediately seek medical attention, suggesting he did not believe his condition was life-threatening. Therefore, the victim’s statements did not qualify as a dying declaration.

Another exception to the hearsay rule is res gestae, which includes statements made spontaneously in connection with a startling event, before the declarant has time to fabricate or contrive a story. To be considered part of res gestae, the statements must concern the event in question and its immediate circumstances. The spontaneity of the statement is crucial, and this depends on several factors, including the time elapsed between the event and the statement, the location, the declarant’s condition, and any intervening events.

The Court determined that the victim’s statements were not part of res gestae because too much time had passed between the alleged assault and his declarations to the witnesses. Also, the victim’s initial denial of any problem before later attributing his injuries to Lagao suggested a lack of spontaneity. The Court cited People v. Jorolan, stating that there must be no intervening circumstance between the startling occurrence and the statement of such nature as to divert the mind of the declarant, and thus restore his mental balance and afford opportunity for deliberation.

The Supreme Court also highlighted a crucial discrepancy regarding the cause of the victim’s death. The Death Certificate indicated the victim died of respiratory failure secondary to sepsis, with underlying causes related to pancreatitis and pneumonia. This conflicted with the testimony of Dr. Parado, who performed the autopsy and stated the cause of death was cardio-respiratory arrest due to hypovolemic shock from a head injury. This contradiction created doubt about the actual cause of death, further weakening the prosecution’s case.

Under the equipoise rule, when the evidence is evenly balanced, the accused must be acquitted. The Court applied this rule, noting that the conflicting evidence regarding the cause of death raised the possibility that the victim died of natural causes, not from the alleged assault by Lagao. Without conclusive evidence linking Lagao’s actions to the victim’s death, the prosecution failed to prove guilt beyond a reasonable doubt.

This case underscores the importance of the prosecution meeting its burden of proof beyond a reasonable doubt, relying on credible and admissible evidence. The Supreme Court held that the lower courts erred in admitting and relying on hearsay evidence that did not fall under any recognized exception. This emphasis on evidentiary standards safeguards the constitutional right to be presumed innocent and ensures that convictions are based on reliable evidence and sound legal principles.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution presented sufficient and admissible evidence to prove beyond a reasonable doubt that Benjie Lagao committed homicide. The Supreme Court focused on the admissibility of hearsay evidence and the conflicting medical evidence regarding the cause of death.
What is hearsay evidence, and why is it generally inadmissible?	Hearsay evidence is testimony or documents quoting persons who are not present in court. It is generally inadmissible because the person who made the original statement was not under oath and could not be cross-examined, making the statement unreliable.
What is a dying declaration, and what are its requirements?	A dying declaration is a statement made by a person who believes they are about to die, concerning the cause and circumstances of their impending death. It is admissible if the declarant is conscious of their impending death, competent as a witness, and the statement is offered in a homicide or murder case.
What is res gestae, and how does it apply to hearsay evidence?	Res gestae refers to statements made spontaneously as part of a startling event, before the declarant has time to fabricate. Such statements are admissible as an exception to the hearsay rule because they are considered reliable due to their spontaneity.
Why did the victim’s statements not qualify as a dying declaration in this case?	The victim’s statements did not qualify because there was no evidence he believed his death was imminent when he made them. His actions, such as continuing to drink and not seeking immediate medical attention, suggested he did not perceive his condition as life-threatening.
Why were the victim’s statements not considered part of res gestae?	The statements were not considered res gestae because they were not made spontaneously and immediately after the alleged assault. Too much time had passed, and the victim had engaged in other activities, providing an opportunity for reflection and potential fabrication.
What is the equipoise rule, and how did it apply in this case?	The equipoise rule states that if the evidence is evenly balanced, such that the court cannot determine guilt beyond a reasonable doubt, the accused must be acquitted. In this case, the conflicting medical evidence regarding the cause of death triggered the application of this rule.
What was the significance of the conflicting medical evidence?	The conflicting medical evidence created reasonable doubt about whether the victim’s death was caused by the alleged assault or by other medical conditions. This uncertainty weakened the prosecution’s case and supported the acquittal of the accused.

The Supreme Court’s decision in Garcia v. People serves as a potent reminder of the high evidentiary standards required in criminal prosecutions. It reinforces the principle that convictions must be based on admissible, reliable evidence and that any reasonable doubt must be resolved in favor of the accused. This ruling helps ensure the protection of individual rights and the integrity of the Philippine justice system.

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: Benjie Lagao y Garcia v. People, G.R. No. 217721, September 15, 2021