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  • Facts: On 28 June 1993, Luis and Rogelio "Boy" Corcolon Approached Eileen Sarmenta and

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    Mamerto Egargo Jr.
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    The Supreme Court affirmed the conviction of Mayor Antonio Sanchez and others for the rape and murder of Eileen Sarmenta and Allan Gomez in 1993. The Court found that while the case received extensive publicity, pervasive publicity alone does not prove the trial judge was impartial. There was no evidence the judge was unduly influenced or developed actual bias against the accused. The accused failed to prove the publicity so permeated the judge's mind that it impaired his impartiality. The Court upheld the conviction, finding the publicity did not fatally infect the judge's impartiality or prove he acquired a fixed position incapable of change.

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    People v Sanchez

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    The Supreme Court affirmed the conviction of Mayor Antonio Sanchez and others for the rape and murder of Eileen Sarmenta and Allan Gomez in 1993. The Court found that while the case received extensive publicity, pervasive publicity alone does not prove the trial judge was impartial. There was no evidence the judge was unduly influenced or developed actual bias against the accused. The accused failed to prove the publicity so permeated the judge's mind that it impaired his impartiality. The Court upheld the conviction, finding the publicity did not fatally infect the judge's impartiality or prove he acquired a fixed position incapable of change.

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    433 views3 pages

    Facts: On 28 June 1993, Luis and Rogelio "Boy" Corcolon Approached Eileen Sarmenta and

    Uploaded by

    Mamerto Egargo Jr.
    The Supreme Court affirmed the conviction of Mayor Antonio Sanchez and others for the rape and murder of Eileen Sarmenta and Allan Gomez in 1993. The Court found that while the case received extensive publicity, pervasive publicity alone does not prove the trial judge was impartial. There was no evidence the judge was unduly influenced or developed actual bias against the accused. The accused failed to prove the publicity so permeated the judge's mind that it impaired his impartiality. The Court upheld the conviction, finding the publicity did not fatally infect the judge's impartiality or prove he acquired a fixed position incapable of change.

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    © All Rights Reserved
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    of 3

    THE PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v.

    MAYOR
    ANTONIO L. SANCHEZ, GEORGE MEDIALDEA, ZIOLO AMA,
    BALDWIN BRION, LUIS CORCOLON, ROGELIO CORCOLON,
    and PEPITO KAWIT, accused-appellants.
    [G.R. No. 121039-45. January 25, 1999]

    Facts: On 28 June 1993, Luis and Rogelio "Boy" Corcolon approached Eileen Sarmenta and
    Allan Gomez, forcibly took the two and loaded them at the back of the latter's van, which
    was parked in front of Café Amalia, Agrix Complex, Los Banos, Laguna. George Medialdea,
    Zoilo Ama, Baldwin Brion and Pepito Kawit also boarded the van while Aurelio Centeno
    and Vicencio Malabanan, who were also with the group, stayed in the ambulance. Both
    vehicles then headed for Erais Farm situated in Barangay Curba, which was owned by
    Mayor Antonio Sanchez of Calauan, Laguna.
    The two youngsters were then brought inside the resthouse where Eileen was taken to
    the Mayor’s room. Allan was badly beaten up by Luis, Boy, Ama and Medialdea and
    thereafter thrown out of the resthouse. At around 1:00 a.m. of the next day, a crying
    Eileen was dragged out of the resthouse by Luis and Medialdea – her hair disheveled,
    mouth covered by a handkerchief, hands still tied and stripped of her shorts. Eileen and
    Allan were then loaded in the Tamaraw van by Medialdea, et. al. and headed for Calauan,
    followed closely by the ambulance. En route to Calauan, gunfire was heard from the van.
    The van pulled over whereupon Kawit dragged Allan, whose head was already drenched
    in blood, out of the vehicle onto the road and finished him off with a single gunshot from
    his armalite.
    The ambulance and van then sped away. Upon reaching a sugarcane field in Sitio Paputok,
    Kilometro 74 of Barangay Mabacan, Eileen was gang-raped by Luis Corcolon, Medialdea,
    Rogelio Corcolon, Ama, Brion and Kawit. After Kawit’s turn, Luis Corcolon shot Eileen with
    his baby armalite. Moments later, all 8 men boarded the ambulance and proceeded to
    Calauan, leaving the Tamaraw van with Eileen’s remains behind. Initially, the crime was
    attributed to one Kit Alqueza, a son of a feared general (Dictador Alqueza). Luis and
    Rogelio Corcolon were also implicated therein. However, further investigation, and
    forensic findings, pointed to the group of Mayor Sanchez. Centeno and Malabanan
    bolstered the prosecution's theory.
    On 11 March 1995, Judge Harriet O. Demetriou of the Regional Trial Court (Pasig City,
    Branch 70) found Mayor Sanchez, Medialdea, Ama, Brion, Luis Corcolon, Rogelio Corcolon
    and Kawit guilty beyond reasonable doubt of the crime of rape with homicide, ordering
    them to pay Eileen Sarmenta the amount of P50,000 and additionally, the amount of
    P700,000.00 to the heirs of Eileen Sarmenta and Allan Gomez as additional indemnity
    On 25 January 1999, the Supreme Court, through Justice Martinez, affirmed in toto the
    judgment of conviction rendered by the trial court. Antonio Sanchez, Zoilo Ama, Baldwin
    Brion and Pepito Kawit seasonably filed their respective motions for reconsideration. The
    Office of the Solicitor General filed its Comment on 6 December 1999. Sanchez avers that
    he is a victim of trial and conviction by publicity, besides claims that principal witness
    Centeno and Malabanan lack credibility, that the testimony of his 13- year old daughter
    should have been given full faith and credit, and that the gargantuan damages awarded
    have no factual and legal bases. Ama, Brion and Kawit maintain that Centeno and
    Malabanan were sufficiently impeached by their inconsistent statements pertain to
    material and crucial points of the events at issue, besides that independent and
    disinterested witnesses have destroyed the prosecution’s version of events. On 2
    February 1999, Justice Martinez retired in accordance with AM 99-8-09. The motions for
    reconsideration was assigned to Justice Melo for study and preparation of the
    appropriate action on 18 September 2001.
    Issue: Whether the publicity of the case impaired the impartiality of the judge handling
    the case.
    Held: Pervasive publicity is not per se prejudicial to the right of an accused to fair trial.
    The mere fact that the trial of Mayor Sanchez, et. al., was given a day-to-day, gavel-to-
    gavel coverage does not by itself prove that publicity so permeated the mind of the trial
    judge and impaired his impartiality. The right of an accused to a fair trial is not
    incompatible to a free press. Responsible reporting enhances an accused's right to a fair
    trial. 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. Our judges are learned in the law and trained to
    disregard off-court evidence and on camera performances of parties to a litigation. Their
    mere exposure to publications and publicity stunts does not per se fatally infect their
    impartiality. To warrant a finding of prejudicial publicity, there must be allegation and
    proof that the judges have been unduly influenced by the barrage of publicity. Records
    herein do not show that the trial judge developed actual bias against Mayor Sanchez, et.
    al., as a consequence of the extensive media coverage of the pre-trial and trial of his case.
    The totality of circumstances of the case does not prove that the trial judge acquired a
    fixed position as a result of prejudicial publicity which is incapable of change even by
    evidence presented during the trial. Mayor Sanchez, et. al., has the burden to prove this
    actual bias and he has not discharged the burden.

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