Tajanlangit, Jeiel J.

Legal Research

People v. Sanchez
GR No 121039-45, January 25, 1999

Case Digest:

Facts:
On June 28, 1993, Medialdea , Centeno who was driving an ambulance, fetched Malabanan, Ama , and
Luis Corcolon from their respective homes on the pretext that they will apprehend one notorious gun
runner and drug pusher in their locality. On board the ambulance, the gang made several stopovers until
they headed back to Calauan past 7 PM upon orders of Luis Corcolon. Subsequently, they met and
picked up Rogelio Corcolon, Kawit and Brion in a gasoline station and headed to UP Los Baños campus
where they abducted Eileen, a UPLB student whom the Calauan mayor was fond of and its companion,
Allan. All of them boarded on the Tamaraw van originally drove by the captives except for Centeno and
Malabanan who stayed in the ambulance. Both vehicles then headed to a farm owned by the mayor in
Barangay Curba.
Upon their arrival, the abductors presented Eileen to the mayor as a gift. However, when he asked
about Allan, they replied “we brought him along to avoid complications”. On that same night, Eileen was
raped by the mayor. Around 1 AM of the next day, Eileen and a beaten Allan were brought by the
abductors back to Calauan. En route, Allan was shot by one of the perpetrators and left at the road. On
a sugarcane field in Sitio Paputok, the group took turns in raping Eileen except for Centeno. After the
sexual fiasco, Luis muted Eileen’s cry by muting forcing an object into her mouth and then fired his baby
armalite at her. Moments later, all 8 men boarded the ambulance and speed away, leaving the
Tamaraw van with Eileen’s remains behind.
After thorough investigation and prolonged trial, the RTC found Calauan Mayor Antonio Sanchez,
George Medialdea, Luis and Rogelio Corcolon, Zoilo Ama, Baldwin Brion and Pepito Kawit guilty for the
crime of rape with homicide plus sums by way of civil indemnity.
Among the many averments to the Court is Sanchez ’contention that he is a victim of trial and conviction
by publicity and questions the credibility of the witness Centeno and Malabanan whose open narrations
served as principal basis for the trial court’s rendition of a “guilty” verdict.
Issue:
1. Whether or not the inconsistencies marred in Cententeno and Malabanan’s testimony constitutes
capriciousness thus should not be a basis for the “guilty” verdict?
2. Whether or not the publicity given to the case impaired the appellant’s right to fair trial?
Ruling:
1. No. So oftenly repeated by [this] Court is that the matter of assigning values to declarations on the
witness stand is best and most competently performed by the trial judge who had the unmatched
opportunity to observe the witnesses and to assess their credibility by the various indicia available but
not reflected in the record. The demeanor of the person on the stand can draw the line between fact
and fancy. The forthright answer or the hesitant pause, the quivering voice or the angry tone, the
flustered look or the sincere gaze, the modest blush or the guilty blanch – these can reveal if the witness
is telling the truth or lying in his teeth. Judge Demetriou who presided over the entire trial until its very
conclusion expressed her satisfaction with the way witnesses’ Centeno and Malabanan survived the
“hot seat” with flying colors, so to speak.

To further fortify this observation, we advert to that all-too familiar rule that discrepancies between
sworn statements and testimonies made at the witness stand do not necessarily discredit the
witnesses. Sworn statements/affidavits are generally subordinated in importance to open court
declarations because the former are often executed when an affiant’s mental faculties are not in such a
state as to afford him a fair opportunity of narrating in full the incident which has
transpired. Testimonies given during trials are much more exact and elaborate. Thus, testimonial
evidence carries more weight than sworn statements/affidavits.
Equally settled is the rule that inconsistencies in the testimony of witnesses when referring only to
minor details and collateral matters do not affect either the substance of their declaration, their
veracity, or the weight of their testimony. Although there may be inconsistencies on minor details, the
same do not impair the credibility of the witnesses where there is consistency in relating the principal
occurrence and positive identification of the assailants, as in this case. Slight contradictions in fact even
serve to strengthen the sincerity of a witness and prove that his testimony is not rehearsed. They are
fail-safes against memorized perjury. Besides, errorless testimonies cannot be expected especially when
a witness is recounting details of a harrowing experience. Even the most truthful witnesses can make
mistakes but such innocent lapses do not necessarily affect their credibility. Consequently, Centeno’s
and Malabanan’s credibility still remains intact notwithstanding these inconsistencies.
2. No. In ruling on this issue, the Court revisited the case of People v. Teehankee, Jr., viz: We cannot
sustain appellant’s claim that he was denied the right to impartial trial due to prejudicial publicity. It is
true that the print and broadcast media gave the case at bar pervasive publicity, just like all high profile
and high stake criminal trials.
Then and now, the Court ruled that the right of an accused to a fair trial is not incompatible to a free
press. To be sure, responsible reporting enhances an accused’s right to a fair trial for, as well pointed
out, ‘a responsible press has always been regarded as the handmaiden of effective judicial
administration, especially in the criminal field. The press does not simply publish information about
trials but guards against the miscarriage of justice by subjecting the police, prosecutors, and judicial
processes to extensive public scrutiny and criticism.’

Legal Opinion:
I couldn’t agree more on the Court’s ruling.
There is no denial that this very case send chills down to my spine with rage and anger. I cannot fathom
how a human being with sound mind could do such crime. But as a potential lawyer, I need to calm
myself up and rely more on what the law has to say on this issue to deliver justice fairly;
Indeed, the Supreme Court is not a trier of facts. It is the lower courts who has the prerogative of
collecting, verifying and assessing whether the facts is sufficient, relevant and complete. When a case
reached the highest court, the honorable justices verily relies on the facts gathered and presented to
them by the inferior courts, in making sound decisions. Thus, herein appellants of this case cannot
challenge the credibility of the star witness since it is expertise of the lower court’s judge, an appointed
combatant of justice by the president, whom had several years of expertise in her field has verified the
competency of the said witnesses. Also, the Supreme Court itself ruled that the irregularity in the
statements/affidavits and testimonies does not necessarily discredit the witness. Then again, there’s
more to the behavior of a witness in a court hearing where the judge can attest whether the witness is
telling lies or truth.
On the matter of the case’ publicity which according to the appellants impaired their right to fair trial, I
strongly disagree. It is not surprising that the case caught the attention of the media given the gruesome
turn of events. This argument is absurd. I believe the Court is independent from whatever media or
public influence. Our justice system relies on laws and jurisprudence, not what the media or public has
to say. The media is only a supplementary means to gather and spread information faster and more
convenient.
 In The Matter of the Charges of Plagiarism, etc., Against Associate Justice Mariano C. Del Castillo

AM No. 10-7-17 SC, February 8, 2011

Case Digest:

Facts:

Petitioners of this case who are all members of the Malaya Lolas Organization sought reconsideration to
the Court for its October 12, 2010 decision dismissing Justice Mariano Del Castillo for the charge of
plagiarism and gross neglect in connection with the decision he wrote in the case of Vinuya v. Romulo,
GR No. 162230. Mainly, petitioners claim that the Court has by its decision legalized or approved of the
commission of plagiarism in the Philippines.

Issue:

Whether or not Justice Mariano Del Castillo committed plagiarism in writing the case of Vinuya v.
Romulo?

Ruling:

No. The Court found that in Vinuya, Justice Del Castillo examined and summarized the facts as seen by
the opposing sides in a way that no one has ever done. He identified and formulated the core of the
issues that the parties raised. And when he had done this, he discussed the state of the law relevant to
their resolution. It was here that he drew materials from various sources, including the three foreign
authors cited in the charges against him. He compared the divergent views these present as they
developed in history. He then explained why the Court must reject some views in light of the peculiar
facts of the case and applied those that suit such facts. Finally, he drew from his discussions of the facts
and the law the right solution to the dispute in the case. On the whole, his work was original. He had but
done an honest work.

Although it is true that Justice Del Castillo failed to attribute to the foreign authors materials that he
lifted from their works and used in writing the decision for the Court in the Vinuya case. But, as the
Court said, the evidence as found by its Ethics Committee shows that the attribution to these authors
appeared in the beginning drafts of the decision. Unfortunately, as testified to by a highly qualified and
experienced court-employed researcher, she accidentally deleted the same at the time she was cleaning
up the final draft. The Court believed her since, among other reasons, she had no motive for omitting
the attribution. The foreign authors concerned, like the dozens of other sources she cited in her
research, had high reputations in international law. Notably, those foreign authors expressly attributed
the controversial passages found in their works to earlier writings by others. The authors concerned
were not themselves the originators.

As it happened, although the ponencia of Justice Del Castillo accidentally deleted the attribution to
them, there remained in the final draft of the decision attributions of the same passages to the earlier
writings from which those authors borrowed their ideas in the first place. In short, with the remaining
attributions after the erroneous clean-up, the passages as it finally appeared in the Vinuya decision still
showed on their face that the lifted ideas did not belong to Justice Del Castillo but to others. He did not
pass them off as his own.

Legal Opinion:

There are no existing rules governing plagiarism in this country so it is quiet difficult to determine
whether someone was indeed committing plagiarism given the different circumstances. But on this case,
I believe Justice Del Castillo should be guilty of plagiarism. It is easy to say that someone deleted the
citations or any justification to dodge the complaint, but I strongly believe that there should be no
rationalization allowed in assessing whether someone committed plagiarism or not. Ponentes should be
very much careful in writing their decisions, given that they are the Supreme Court justices writing a
material vital and crucial to every citizen in this country and in the field of law.