110290) counsel of one's choice and the requirement of a
In the case of People v. Agustin, the court ruled that the written waiver of the right to counsel. appellant's extrajudicial admission was obtained in violation Emphasized the importance of understanding the of his constitutional rights and is inadmissible as evidence, appellant's language and doubts about the emphasizing the importance of meaningful information appellant's understanding of his constitutional transmission and explicit information about the right to rights. counsel. Concluded that the appellant's extrajudicial admission was obtained in violation of his Facts: constitutional rights and is inadmissible as Appellant, Jaime "Jimmy" Agustin, charged with evidence. murder in connection with the deaths of Dr. Napoleon Bayquen and Anna Theresa Francisco, as PEOPLE VS TIZON (G.R. No. 133228-31) well as the attempted murder of Anthony Facts: Bayquen, Dominic Bayquen, and Danny Ancheta. The accused-appellants, Godofredo Tizon, Jr., Crimes allegedly committed on September 6, 1986, Randy Ubag, Arnold Ladrillo, and Nestor in Baguio City. Crisostomo, were found guilty of four counts of Appellant and Wilfredo "Sonny" Quia o were the rape each and were sentenced to reclusion only ones arrested, but Quia o escaped while perpetua. under custody. The conviction was based on their extrajudicial Appellant pleaded not guilty. confessions, which were deemed admissible by the Trial court acquitted appellant of charges of trial court. frustrated murder and attempted murder but The accused claimed that their confessions were convicted him of two counts of murder. obtained in violation of their constitutional rights Court sentenced him to reclusion perpetua and because they were made before a lawyer chosen ordered him to pay indemnity to the victims' heirs. by the police and they were induced by a promise Issue: of leniency by the police station commander. Whether the extrajudicial admission of the Issue: appellant is admissible as evidence against him. Whether the extrajudicial confessions of the Ruling: accused were obtained in violation of their The extrajudicial admission of the appellant is constitutional rights. inadmissible as evidence against him. Ruling: Appellant's constitutional rights were violated The Supreme Court affirmed the conviction of the during the investigation, resulting in the accused. involuntary and unintelligent nature of his The court ruled that a lawyer chosen by the police admission. is deemed engaged by the accused if they did not Right to be informed of the right to remain silent object to the lawyer's appointment and voluntarily and to counsel requires meaningful information executed their confessions. transmission, not just a ceremonial recitation of The court also ruled that the trial court's finding the constitutional principle. that the accused were accorded a competent and Appellant was not explicitly informed of his right to independent counsel is entitled to respect. have a competent and independent counsel of his The promise of leniency by the police station choice, and no written waiver of his right to commander did not render the confessions counsel was presented. inadmissible. Counsel who represented the appellant was not an Ratio: "independent" counsel, as he was an associate of The accused had the final choice of their lawyer the private prosecutor in the case. and they voluntarily executed their confessions Doubts about the appellant's understanding of his without objecting to the lawyer chosen by the constitutional rights, as the explanations were police. given in English and Tagalog, while the appellant The trial court's finding that the accused were only understood Ilocano. accorded a competent and independent counsel is Appellant's extrajudicial admission was obtained in entitled to respect. violation of his constitutional rights and is The promise of leniency by the police station inadmissible as evidence. commander, who is not a prosecuting officer, did Ratio: not render the confessions inadmissible. Decision based on the violation of the appellant's constitutional rights during the investigation. PEOPLE VS TUJON (G.R. No. 66034) Emphasized the importance of meaningful Facts: information transmission when informing a person The case involves the accused-appellant Jovito of their right to remain silent and to counsel. Tujon who was charged with the crime of Robbery Highlighted the need for explicit information about with Homicide. the right to have a competent and independent The victim, Rolando Abellana, a taxi driver, was found dead with stab wounds in Quezon City. The accused, along with Ernesto Parola and Cesar Issue: Paredes, were arrested and allegedly confessed to Whether Ponseca's confession was obtained the crime during police interrogation. through force and torture. The Court of First Instance of Rizal, Seventh Whether Ponseca's confession was admissible as Judicial District, Quezon City, found Tujon and evidence. Parola guilty beyond reasonable doubt and Ruling: sentenced them to reclusion perpetua. The Supreme Court affirmed Ponseca's conviction. Parola escaped from jail and remained at large. The court ruled that Ponseca failed to prove that Issue: his confession was obtained through force and Whether the extra-judicial confessions of the violence. accused, taken without the presence of counsel, The court stated that a confession is admissible are admissible as evidence. until the accused successfully proves that it was Ruling: given as a result of violence, intimidation, threat, The confessions are inadmissible as evidence. or promise of reward or leniency. The accused were not properly informed of their Ponseca only made bare allegations without rights and the waiver of counsel, if made at all, was presenting any proof of coercion. not made with the assistance of counsel. The court also found that Ponseca's confession Therefore, the confessions cannot be considered was supported by other competent evidence, such as credible evidence. as the testimony of a witness who identified The Court acquitted both accused. Ponseca and his co-accused as the perpetrators of Ratio: the crime. The right of a person under custodial interrogation Therefore, the court concluded that Ponseca's to be informed of his right to remain silent and to confession was admissible and upheld his counsel implies a correlative obligation on the part conviction. of the police investigator to explain and ensure Ratio: effective communication. Once the prosecution has shown compliance with In this case, the accused were not properly the constitutional requirement on pre- informed of their rights and the waiver of counsel, interrogation advisories, a confession is presumed if made at all, was not made with the assistance of to be voluntary. The burden is on the accused to counsel. prove that the confession was involuntary. Therefore, the confessions cannot be considered Ponseca failed to present any proof that force and as credible evidence. violence were employed to coerce him into The Court also noted that there was no other confessing. He did not undergo a medical evidence presented by the prosecution to establish examination, did not complain to his relatives or the guilt of the accused beyond reasonable doubt. the prosecutor, and did not file any complaint In weighing the evidence, the scales must be against the police officers. tipped in favor of the accused due to the Ponseca's confession was supported by other constitutional presumption of innocence. evidence, such as the testimony of a witness who As a result, the Court acquitted both accused. identified him and his co-accused as the Despite Parola's escape from jail, he still benefits perpetrators of the crime. from the acquittal as the evidence against him was Accused-appellant's confession was obtained with not proven beyond reasonable doubt. the assistance of a lawyer, and the lawyer testified The Court acknowledged his act of escaping as an that he informed Ponseca of his constitutional act of defiance of the law but recognized that rights and assisted him during the custodial there have been cases where such conduct is investigation. driven by a sense of desperation of those who The confession contained details that only a believe they are innocent but fear they cannot participant in the crime would know, further prove their innocence. supporting its credibility. The court found no reason to alter the trial court's PEOPLE VS LADAO (G.R. No. 100940-41) judgment of conviction and affirmed Ponseca's Facts: guilt for robbery with homicide. Henry Ponseca and his co-accused were The court modified the civil liability by increasing apprehended by the Caloocan Police for several the indemnity to the victim's heirs to P50,000.00 robbery and hold-up incidents in Caloocan. and deleting the award for burial and wake They executed an extra-judicial confession with expenses due to lack of basis. the assistance of a lawyer from the Public Attorney's Office, admitting their involvement in PEOPLE VS ENCIPIDO (G.R. No. 70091) the crime. Facts: Based on the confession and circumstantial The case involves the conviction of eight evidence, the trial court convicted all five accused, individuals for murder. including Ponseca, and sentenced them to The defendants are Brigido Encipido, Charlito reclusion perpetua. Manatad, Jesus Rubio, Rudy Lumarda, Jose Cabageran, Eddie de la Peña, Cris Ramire, and assault upon agents of persons in authority. The Jesus or John Doe. accused, including Tambutso Patuhin, Jayri Jamari, The incident took place on March 30, 1982, in Tambusong Mohamadsali, and Samindi Cosing, Barangay Mabini, Tubajon, Surigao del Norte. were charged with the crime. The incident The victim, Jose Lacumbes, was found killed near occurred on April 7, 1967, in the municipality of his hut. Peaplata, Samal, Davao. The accused were caught The autopsy revealed multiple injuries on the dynamite fishing, and when they were arrested, victim's body. they were towed by a PC motorboat. Another Issue: motorboat intercepted the PC motorboat, and the The main issue is the credibility of the witnesses accused in the second motorboat threw dynamite and the admissibility of the oral confessions made sticks at the PC motorboat, causing the death of by the defendants. the victims. The accused were apprehended, and Ruling: they confessed to their participation in the crime. The court upheld the conviction of the defendants for murder. Issue: Ratio: Whether the accused participated in the material The court ruled that minor inconsistencies in the execution of the acts that caused the death of the witness's testimony did not affect his credibility. victims. The witness's description of the incident was Whether there was a criminal conspiracy among consistent with the testimonies of other witnesses the accused and the persons who actually killed and supported by the autopsy findings. the victims. The court stated that omissions and Whether Sapal Jabal should be convicted as an misunderstandings are common in affidavits and accessory to the crime. do not undermine the witness's credibility. Whether the extra-judicial confessions of the The court held that the oral confessions made by accused are admissible as evidence. Encipido and De la Peña were admissible as Ruling: evidence against them under Sections 22 and 29 of The lower court did not err in convicting the the Rules of Court. accused. Although some of the accused claimed in The confessions were independently made their statements that they did not hit the PC without collusion, were identical in their material motorboat, the court found that there was a respects, and were corroborated by other concert of action among the accused, and they evidence. were responsible for throwing dynamite sticks that The court noted that the confessions could be caused the deaths of the victims. considered as circumstantial evidence against the The lower court did not err in convicting the co-accused implicated therein and as accused of criminal conspiracy. The court found corroborative evidence against the others involved that there was evidence of conspiracy among the in the crime. accused, as they acted together in throwing The court rejected the argument that the dynamite sticks at the PC motorboat. testimonies regarding the oral confessions The issue of Sapal Jabal being convicted as an constituted hearsay, stating that oral confessions accessory is not considered since he was not an can be proved by any competent witness who appellant and has passed away. heard them. The lower court did not err in admitting the extra- The court emphasized that any person who heard judicial confessions of the accused as evidence. the confession and understood it is competent to The confessions were found to be given freely and testify as to its substance. voluntarily, and the fact that the accused did not The defense of alibi raised by Encipido and complain of duress or violence supports their Manatad was dismissed by the court. voluntariness. The positive identification by the witness, their Ratio: verbal acknowledgments of guilt, and the The court based its decision on the evidence confessions made by De la Peña provided strong presented, including the extra-judicial confessions evidence against them. of the accused. The court found that the The court noted that the defense failed to prove confessions were given voluntarily and that there that they were at a different location at the time of was no evidence of duress or violence. The court the crime. also found that there was a concert of action The court affirmed the conviction of the among the accused, indicating a criminal defendants for murder and increased the civil conspiracy. Therefore, the accused were convicted indemnity to P30,000. of the crimes charged.
PEOPLE VS JALJALANI (G.R. No. L-29979)
Facts: HEARSAY RULE:PEOPLE VS VALERO (G.R. No. L-45283-84) This case involves the multiple murder of two PC Facts: soldiers and one civilian, as well as the direct The case involves the charge of double murder and Accused Basilio Damaso was charged with illegal frustrated murder against Lucila Valero for possession of firearms in connection with the allegedly giving poisoned bread to the crime of subversion. complainant's children, two of whom died while The case was filed before the Regional Trial Court another would have died if not for timely medical of Dagupan City. assistance. The case against Alfonsito Valero, a The prosecution presented testimonies from deaf-mute who did not understand the witnesses claiming that the accused was the lessee proceedings against him, was dismissed. The of the house where the firearms were found. prosecution and defense had conflicting views on However, these testimonies were hearsay and the source of the poisoned bread. The prosecution lacked personal knowledge. presented witnesses who claimed that Lucila gave The defense argued that the search conducted by the bread to Alfonsito, who then delivered it to the the authorities was illegal as it was done without a children. The defense argued that the children may warrant and without the consent of the accused. have eaten the poisoned bread intended for rats. Issue: The trial court found Lucila guilty based on the Whether the evidence presented by the prosecution's evidence and her psychiatric prosecution is sufficient to prove the guilt of the abnormality, sentencing her to death. accused beyond reasonable doubt. Issue: Whether the search conducted by the authorities The main issue in this case is whether the was legal. admission of the prosecution's evidence, which Ruling: relied on hearsay and violated the accused's right The court ruled in favor of the accused and to confront witnesses, was a gross violation of the acquitted him. hearsay rule and the accused's constitutional The evidence presented by the prosecution was rights. weak and insufficient to prove the guilt of the Ruling: accused beyond reasonable doubt. The Supreme Court held that the admission of the Hearsay evidence, whether objected to or not, prosecution's evidence, which relied on hearsay cannot be given credence. and violated the accused's right to confront The right against unreasonable searches and witnesses, was a gross violation of the hearsay rule seizures is enshrined in the Constitution and and the accused's constitutional rights. The court cannot be waived by anyone except the person also found that the trial judge's conjecture on whose rights are invaded. probable cause was a denial of due process. As a The search conducted by the authorities was illegal result, the judgment was reversed, and Lucila was as it was done without a warrant and without the acquitted. consent of the accused. Ratio: Ratio: The court ruled that the presentation of witnesses The court emphasized that the evidence presented who conveyed information obtained from a deaf- by the prosecution was weak and insufficient to mute through sign language violated the hearsay prove the guilt of the accused beyond reasonable rule and the principle of res inter alios acta. The doubt. The testimonies of the witnesses were court also found that the admission of such hearsay and lacked personal knowledge. Hearsay evidence as part of the res gestae was unjustified. evidence, whether objected to or not, cannot be The failure of the defense counsel to object to the given credence as it does not meet the standard of presentation of incompetent evidence did not give proof required in criminal cases. it any probative value. The court emphasized that The court highlighted that the right against the admission of testimonies, whether hearsay or unreasonable searches and seizures is enshrined in part of the res gestae, for the imposition of the the Constitution. This right protects individuals death penalty violated the accused's right to from arbitrary invasions of their privacy and confront witnesses. The court further noted that property. It can only be waived by the person the extrajudicial information obtained from an whose rights are invaded, and not by anyone else. incompetent witness was inadmissible. The court In this case, the search conducted by the also found that the absence of a natural reaction authorities was done without a warrant and from a witness negated his credibility. Additionally, without the consent of the accused, making it the court found that the absence of a motive for illegal. the accused to poison the children weakened the Based on these reasons, the court concluded that prosecution's case. Finally, the court held that the the evidence presented by the prosecution was trial judge's sudden conjecture on the accused's weak and insufficient, and the search conducted psychiatric abnormality in his decision was a denial by the authorities was illegal. Therefore, the of due process. accused was acquitted.
PEOPLE VS DAMASO (G.R. No. 93516)
Agcaoili v. Molina (AM 94-979, October 25, 1995) Facts: Facts: 1. Complainant Judge Emerito M. Agcaoili filed a The incident occurred on December 23, 1966, case charging Judge Adolfo B. Molina with grave in the Municipality of Tayum, Province of ignorance of the law in relation to Criminal Case No. Abra, Philippines. The defendants were accused of assaulting 10-435, entitled "People of the Philippines v. and shooting Silvino Daria, resulting in his Rolando Anama," for homicide. death. 2. The Complainant judge alleged that respondent, The motive for the killing was the disapproval in conducting the preliminary investigation of the of Mariano Taeza's courtship of the victim's above-mentioned criminal case, failed to exercise daughter. Witnesses testified to seeing the defendants utmost care in the issuance of a warrant of arrest pointing guns at the victim's house and against the accused relying merely on the hearing gunshots. statements of two (2) witnesses who had no The victim's wife also testified that her personal knowledge of the commission of the husband identified the defendants as his offense charged. shooters before he died. The defendants pleaded alibi as their defense, 3. Respondent admitted that he was the inquest claiming they were elsewhere at the time of judge in the preliminary investigation of the above the incident. entitled case and finding the existence of probable Issue: cause, he ordered the issuance of the warrant of The main issues raised in the case are: arrest against the accused. Whether the testimony of the prosecution 4. Respondent explained that since the case witness, Cecilia Bernal, is reliable and sufficient to identify the defendants as the washtognizable by the Regional Trial Court, the perpetrators. Provincial Prosecutor's Office, which has the final Whether the affidavit of Antonio Daria, say and disposition on the existence of probable clearing Mariano Taeza, should be considered cause on cases cognizable by the Regional Trial as evidence. Court, should carry the brunt of the responsibility Whether the defendants are guilty of murder. for "erroneous" finding of probable cause. Ruling: The Court affirmed the judgment of the lower 5. The Office of the Court Administrator court, finding the defendants guilty of murder. recommended that respondent be admonished to The penalty of death was reduced to life be more careful in the determination of the imprisonment due to lack of sufficient votes. existence of probable cause before issuing a The amount of indemnity was increased to warrant of arrest. P12,000.00. Ratio: Issue: The testimony of Cecilia Bernal, a witness who Whether or not the respondent judge is correct in saw the defendants pointing guns at the issuing the warrant of arrest. victim's house and heard gunshots, is reliable and sufficient to identify the defendants as the Held: perpetrators. No. An elementary legal principle must not be The affidavit of Antonio Daria, clearing compromised — hearsay evidence cannot be the Mariano Taeza, was rejected as evidence basis of probable cause. The rules on evidence are explicit. A witness can testify only to those facts DYING DECLARATION: PEOPLE VS DE JOYA (G.R. No. 75028) which he knows of his personal knowledge; that is, Facts: which are derived from his own perception.' The case involves the defendant-appellant, Hearsay evidence, therefore, has no probative value Pioquinto de Joya y Cruz, who was charged with whatsoever. Yet, in the case at bench, the the crime of robbery with homicide. The incident respondent judge found probable cause and even occurred on January 31, 1978, in Baliuag, Bulacan. issued an arrest warrant on the basis of the The victims were Arnedo Valencia and Eulalia testimonies of Mencelacion Padamada and Rosita Diamse Vda. de Salac. The defendant allegedly took jewelry from the victims and attacked Eulalia, Castillo which were obviously hearsay. causing her death. The trial court found the defendant guilty and sentenced him to life PEOPLE VS BRIOSO (G.R. No. L-28482) imprisonment. Facts: Issue: The case involves the defendants Juan Brioso The main issue in the case is whether the and Mariano Taeza who were charged with defendant is guilty beyond reasonable doubt of the crime of murder under Article 248 of the the crime of robbery with homicide. Revised Penal Code. Ruling: The Supreme Court ruled in favor of the defendant from the scene of the crime, weakening his and acquitted him of the charges. The court found defense even further. that the dying declaration of the deceased victim The conviction of a person should rest on the was incomplete and therefore not admissible as strength of the prosecution's case, not on the evidence. The court also found that the other weakness of the defense. The accused can rely on circumstantial evidence presented by the the constitutional presumption of innocence, and prosecution was not sufficient to establish the it is the prosecution's burden to overcome this defendant's guilt beyond reasonable doubt. presumption with convincing proof of guilt. In this Ratio: case, the prosecution failed to prove its case The court explained that a dying declaration must beyond reasonable doubt. be complete in itself to be admissible. In this case, A dying declaration, if proven to be true, can be the deceased victim was unable to convey a considered an exception to the hearsay rule. complete or sensible communication before her However, it is still subject to the test of credibility. death. The court could not speculate on what the In this case, the victim allegedly identified Dunig as rest of her communication might have been. her attacker before she died. However, the Therefore, the dying statement could not be resthouse where the incident occurred was dark, considered a dying declaration naming the and the witnesses themselves admitted that they defendant as the perpetrator of the crime. could not see anyone clearly. The identification of The court also found that the other circumstantial Dunig as the killer was uncertain and based on a evidence presented by the prosecution, such as a surmise, which is not considered evidence. quarrel over a bicycle and the defendant's The evidence presented by the prosecution is reluctance to participate in the wake of the victim, weak and cannot sustain a conviction. The did not establish a credible motive or guilt. The testimonies of the alleged eyewitnesses are not court emphasized that a credible motive is believable, as they claimed to have seen the killing necessary when no identification of the defendant in total darkness or near total darkness. was shown. Additionally, the court rejected the prosecution's PEOPLE VS AMACA (G.R. No. 110129) claim of an offer of compromise and implied Facts: admission of guilt by the defendant. The court The case involves accused-appellant Edelciano found that the evidence presented was not Amaca who was convicted of murder and sufficient to support these claims. sentenced to reclusion perpetua. The victim, Wilson Vergara, made a dying declaration to a PEOPLE VD DUNIG (G.R. No. 101799) police officer, positively identifying Amaca as the Facts: killer. The defense of the accused was alibi. The case involves the defendant-appellant, Issue: Pacifico Dunig, who was charged with the murder The main issue raised in the case is whether the of Marilyn Canatoy. The incident occurred on April trial court erred in convicting the accused of 5, 1990, in San Ildefonso, Bulacan, where Dunig murder based solely on the dying declaration of allegedly stabbed and killed the 14-year-old victim. the victim. The prosecution presented three witnesses, Ruling: Maylin Montes, Katherine Montes, and Teresita The appeal is partially granted. The accused is Montes, who claimed to have witnessed the guilty only of homicide, not murder, and civil killing. The defense of Dunig was alibi, stating that indemnity shall not be awarded to the heirs of the he was in a nipa hut in Matinbubong, San deceased. Ildefonso, Bulacan, during the time of the crime. Ratio: Issue: A dying declaration is considered credible because The main issue in this case is whether the it is highly unlikely for someone who is aware of prosecution has proven the guilt of the accused- their impending death to falsely accuse someone appellant beyond reasonable doubt. of being responsible for their death. The victim's statement meets all the requirements for a dying declaration. The serious nature of the victim's injuries did not affect his credibility as a witness Ruling: since he was able The court reverses and sets aside the decision of the trial court, acquitting the accused-appellant US VS ANTIPOLO (G.R. No. L-13109) and ordering his immediate release. Facts: Ratio: Dalmacio Antipolo was prosecuted for the murder Alibi is a weak defense, and in this case, Dunig of Fortunato Dinal. failed to present any witnesses to corroborate his Antipolo was convicted of homicide in the Court of alibi. Furthermore, the nipa hut where he claimed First Instance of the Province of Batangas and to have been sleeping was only a kilometer away appealed the decision. One of the errors raised in the appeal was the appellant unlawfully possessed a firearm and used refusal of the trial judge to allow Susana Ezpeleta, it with treachery and evident premeditation in the widow of the deceased, to testify as a witness shooting and killing Leonardo Bolima. The trial for the defense regarding certain dying court found accused-appellant guilty and declarations made by her husband. sentenced him to life imprisonment. The trial judge sustained the objection of the fiscal, Issue: who argued that as the widow of the deceased, Whether the prosecution was able to prove Ezpeleta was not competent to testify under the accused-appellant's guilt beyond reasonable doubt rules of procedure in civil or criminal cases. for the crimes of illegal possession of firearms and Issue: murder. Is the widow of the deceased a competent witness Ruling: to testify about dying declarations made by her The Supreme Court modified the decision of the husband regarding the cause of his death? trial court and found accused-appellant guilty of Ruling: homicide instead of murder. The court held that The court ruled in favor of the defendant and the prosecution failed to prove that accused- granted a new trial. appellant had no license to possess the firearm, The court held that the widow of the deceased is a which is an essential element of the offense of competent witness in a prosecution regarding illegal possession of firearms. However, the court dying declarations made by the deceased found that accused-appellant was guilty of concerning the cause of his death. homicide based on circumstantial evidence. The Ratio: court also ruled that the qualifying circumstance of The court based its decision on Section 58 of treachery was not proven beyond reasonable General Orders No. 58 (1900), which states that doubt. neither husband nor wife shall be a competent Ratio: witness for or against the other in a criminal action The killing of a person with the use of an or proceeding, except with the consent of both or unlicensed firearm may give rise to separate in cases of crime committed by one against the prosecutions for violation of P.D. No. 1866 and other. violation of the Revised Penal Code for murder or The purpose of this rule is to protect accused homicide. persons against statements made in the The rule against double jeopardy cannot be confidence engendered by the marital relation and invoked because the first offense is punished by a to relieve the spouse to whom such confidential special law while the second offense is punished communications might have been made from the by the Revised Penal Code. obligation of revealing them to the prejudice of Circumstantial evidence can be sufficient to the other spouse. convict an accused if the circumstances proven However, dying declarations made by a deceased constitute an unbroken chain leading to one fair person regarding the circumstances leading up to and reasonable conclusion that points to the their death are admissible in a prosecution of the accused as the guilty person. person charged with killing the declarant. Statements made by a person as part of the res Such dying declarations are admissible in favor of gestae are admissible as an exception to the the defendant as well as against him. hearsay rule. Previous cases in the United States have held that The burden of proof lies on the prosecution to the widow of the deceased may testify regarding prove the lack or absence of a license in cases of his dying declarations. illegal possession of firearms. The communication made by the deceased at the Treachery must be proved by clear and convincing point of death regarding the cause of his injuries is evidence or as conclusively as the killing itself. not confidential and is made for the purpose of An appeal in a criminal case opens the whole case being communicated to the authorities concerned for review, including the penalty, indemnity, and in investigating the cause of his death. damages involved. Therefore, the widow of the deceased is a competent witness to testify about these dying PEOPLE VS NARANJA (G.R. No. L-13288) declarations. Facts: The trial judge erred in excluding the testimony of The accused, Jose Naranja, was charged with and Susana Ezpeleta and a new trial was granted for convicted of murder in the Court of First Instance the accused. of Pangasinan. PART OF RES GESTAE: PEOPLE VS TIOZON (G.R. No. 89823) The information filed against the accused stated Facts: that on December 28, 1956, in barrio Caraol- The case involves accused-appellant Eutropio Malimpin, municipality of Dasol, province of Tiozon y Acid who was charged with violation of Pangasinan, the accused assaulted, attacked, and Presidential Decree (P.D.) No. 1866, as amended, beat to death Mamerto Signey with a blunt for the illegal possession of a firearm and for instrument. murder. The information alleged that accused- The accused appealed the conviction, arguing that The dying declaration did not comply with the the alleged crime has not been established due to requirements for admissibility lack of evidence. The prosecution failed to establish that the victim Issue: made the statements under a consciousness of Whether the elements of the crime of murder impending death have been proven beyond reasonable doubt. No proof that the victim was aware of the Ruling: seriousness of his condition or believed he was The decision of the lower court convicting the going to die accused of murder is affirmed. Alleged statements lacked spontaneity and did not Ratio: qualify as part of the res gestae The testimony of Maria Diaz, the widow of the Testimonies of prosecution witnesses contradicted deceased, is credible and not self-serving. She by defense witnesses and even some of the admitted to having had illicit relations with the prosecution's own witnesses accused in order to bring out the truth that the Ratio: accused confessed to her his plan to kill her The dying declaration did not meet the husband and the fact that he killed him. Her requirements for admissibility testimony is therefore credible and cannot be The prosecution failed to prove that the victim considered self-serving because she gained no made the statements under a consciousness of beneficial interest from it. impending death The confession of the accused to Maria Diaz falls There was no evidence to show that the victim was under the res gestae rule, which allows statements aware of the seriousness of his condition or made by a person while a startling occurrence is believed he was going to die taking place or immediately prior or subsequent The alleged statements lacked spontaneity and did thereto to be given in evidence as part of the res not qualify as part of the res gestae gestae. These statements are admitted as original The testimonies of the prosecution witnesses were evidence, distinguished from hearsay, because of contradicted by the defense witnesses and even by their connection with the principal fact under some of the prosecution's own witnesses investigation. The Supreme Court emphasized that the weakness The testimony of Santiago Balderas, who was told of the accused's alibi cannot be held against them by Maria Diaz that her husband was dead and in the absence of a clear and positive identification could be found at a certain place, further proves as the perpetrators of the crime the fact of the crime as confessed by the accused. The State must rely on the strength of its own The presence of a bluish black spot at the nape of evidence, not the weakness of the defense the deceased and the opinion of Dr. Valera that a Conclusion: blow delivered right on the medulla oblongata The Supreme Court reversed the judgment of the could have caused instantaneous death confirm trial court and acquitted the accused-appellants of the admission of the accused to Maria Diaz. the crime charged. The defense of alibi is weak and not credible. The testimony of the defense witness, Bisquera, is not believable as she could recall the events of December 28, 1956, the date of the crime, but PEOPLE VS RAQUEL (G.R. No. 119005) could remember nothing about other days, not Facts: even Christmas. It is also not impossible for the Accused-appellants Sabas Raquel and Valeriano accused to have been at the ricefield in the Raquel were charged with robbery with homicide. afternoon and still have gone to Maria Diaz's The crime was allegedly committed on July 4, house in the evening to kill her husband, 1986, in Barangay Osias, Kabacan, Cotabato. considering the proximity of the locations. The victims were Agapito Gambalan, Jr. and his wife Juliet Gambalan. PEOPLE VS PALOMONES (G.R. No. 136303) Juliet testified that her husband was shot by Facts: armed men who declared a hold-up. Case title: People v. Palmones She was not able to identify the assailants, but she Accused-appellants charged with the crime of saw one person fall beside their water pump and murder for killing SPO2 Asim Mamansal two others running away. Trial court found the accused guilty and sentenced Witness George Jovillano also saw three persons them to reclusion perpetua passing by but could not recognize them. Prosecution's case relied on alleged dying Accused Amado Ponce, who was wounded and declaration made by the victim, where he found near the crime scene, implicated the Raquel identified the accused as his assailants brothers as his co-perpetrators. Issue: Issue: Whether the dying declaration made by the victim Whether the prosecution was able to establish the is admissible as evidence guilt of the accused-appellants beyond reasonable Ruling: doubt. Ruling: insufficient to overcome the positive identification The court acquitted Sabas Raquel and Valeriano made by the prosecution witness. In this case, Raquel of the crime charged. Maria Teresa positively identified Rodolfo as the The court ruled that the extrajudicial statement of person who raped her on August 29, 1990, and Amado Ponce implicating the appellants was who had been sexually abusing her since she was inadmissible as evidence against them. five years old. The court also noted that Rodolfo's The court emphasized that extrajudicial house was only about 2-1/2 to 3 kilometers away statements of an accused implicating a co-accused from his place of work, which could be reached in cannot be utilized unless repeated in open court. 30 minutes by walking. Therefore, it was not The statement was made without the assistance of physically impossible for him to have been at his counsel, rendering it inadmissible. house where the rape was committed. The court The court applied the res inter alios rule, stating also considered the delicate details in Maria that an extrajudicial confession is binding only Teresa's statements and testimony, which could upon the confessant and not admissible against his only be based on real experience rather than co-accused. imagination. The court emphasized that the The prosecution failed to establish the identities testimony of young and immature rape victims and participation of the appellants beyond deserves full credence. Since Maria Teresa was reasonable doubt. below 12 years old when the rape was committed, Ratio: any carnal knowledge of her, even if consented, Extrajudicial statements of an accused implicating would be considered rape under the law. a co-accused are inadmissible unless repeated in open court. PEOPLE VS DIVINA (G.R. No. 93808-09, 94073-74) Extrajudicial statements made during custodial Facts: investigation without the assistance of counsel are Accused Belarmino Divina and Mecrito Baga were inadmissible. convicted for murder and frustrated murder. An extrajudicial confession is binding only upon The incident occurred on June 17, 1988, in the confessant and not admissible against his co- Barangay Malungcay Daku, Municipality of Dauin, accused. Negros Oriental. A conviction in a criminal case must rest on Accused were charged with shooting Concepcion nothing less than a moral certainty of guilt. Baillo, resulting in her death, and inflicting gunshot Every reasonable doubt in criminal cases must be wounds on Jaime Baillo. resolved in favor of the accused. Trial court found both accused guilty beyond reasonable doubt and sentenced them accordingly. Issue: ENTRIES IN OFFICIAL RECORDS: PEOPLE VS BERNALDEZ Credibility of the lone eyewitness and victim, Jaime (G.R. No. 109780) Baillo. Facts: Defense argues conflicting, uncorroborated, The case involves the conviction of accused- unreliable, and inconclusive testimony. appellant Rodolfo Bernaldez for the crime of rape Defense questions the delay in reporting the committed against his 10-year-old niece, Maria identities of the accused, affecting the credibility Teresa Bernaldez. The incident occurred on August of the witnesses. 29, 1990, at Rodolfo's house in Sitio Mabatia, Ruling: Barangay Sugcad, Polangui, Albay. After the rape, Conviction of accused Belarmino Divina affirmed. Rodolfo gave Maria Teresa P5.00 and threatened Conviction of accused Mecrito Baga overturned her not to tell anyone or he would kill her parents, due to lack of evidence. brothers, and sisters. Maria Teresa also claimed Prosecution failed to establish guilt of Baga that Rodolfo had been sexually abusing her since beyond reasonable doubt. she was five years old. The complaint for rape was Conspiracy not established beyond reasonable filed by Maria Teresa's father, Pedro Bernaldez, on doubt, no evidence of overt act in furtherance of September 3, 1990. conspiracy. Issue: Ratio: The main issue raised in the case is whether Alibi is a weak defense and cannot prevail over Rodolfo Bernaldez is guilty of the crime of rape positive identification by prosecution witnesses. Ruling: Victim Jaime Baillo positively identified Belarmino The Supreme Court affirmed the decision of the Divina as one of the assailants. Regional Trial Court (RTC) convicting Rodolfo Consideration of motive of Divina, victim's mother Bernaldez of rape. was a witness against his brothers in another Ratio: criminal case. The court ruled that the complainant's positive Discrepancy in time of incident stated in police identification of the accused as the perpetrator is blotter explained. decisive in a rape charge. Bare denial and alibi are Entries in official records, such as a police blotter, these considerations, the court concludes that the are only prima facie evidence and not conclusive. guilt of the accused has not been proven beyond Hearsay information supplied by parish priest, not reasonable doubt, and he is entitled to an present during incident, lacks probative value. acquittal. Separate petition for certiorari by Belarmino Divina regarding approval of property bond. PEOPLE VS CRISOSTOMO (G.R. No. L-32243) Court denies petition, accused charged with capital Facts: offense or offense punishable by reclusion On December 25, 1967, Eugenio Crisostomo perpetua not entitled to bail as a matter of right, encountered Romeo Geronimo and invited him to even if they appeal the case to the court have a drink, but Romeo declined. Suddenly, Conclusion: Eugenio rushed towards Romeo, who had his back Accused Mecrito Baga acquitted due to lack of turned, and shot him with a .22 caliber revolver. evidence. The bullet entered Romeo's chest and he fell to Conviction of accused Belarmino Divina affirmed, the ground. Eugenio fled the scene while ordered to indemnify heirs of victim. bystanders brought Romeo to the hospital, where Dismissal of Divina's petition for certiorari he was pronounced dead upon arrival. Eugenio regarding approval of property bond. was charged with murder. Issue: PEOPLE VS LEONES (G.R. No. L-48727) Did Eugenio admit to killing Romeo? Facts: Was the cause of death established? The case involves the defendant-appellant, Joseph Did Eugenio act with treachery? Leones, who was accused of raping Irene Dulay, a Is Eugenio entitled to the mitigating circumstance salesgirl in the store owned by appellant's parents. of drunkenness? The incident allegedly occurred one afternoon Is Eugenio entitled to the mitigating circumstance after the appellant and his sister forced Irene to of voluntary surrender? take three tablets, which rendered her semi- Is Eugenio entitled to the mitigating circumstance conscious. The appellant denied the charges and of a voluntary plea of guilty? claimed that he was at a beach resort with his Is Eugenio entitled to the privileged mitigating family during the time of the alleged rape. circumstance? Ruling: During the trial, medical examination conducted The court found Eugenio guilty of murder and on Irene about two or three hours after the sentenced him to Reclusion Perpetua. The court alleged rape revealed healing lacerations of the also ordered him to pay the victim's heirs P12,000. hymen, absence of sperm cells, and unclotted The decision was affirmed with modifications, blood at the vaginal cavity. However, Irene increasing the indemnity to P30,000. testified that she was having her menstrual period Ratio: on the date of the alleged rape. Eugenio effectively admitted to shooting Romeo, Issue: as he testified that he played a joke on him by The main issue in the case is whether the guilt of pointing his gun, which accidentally went off and the accused, Joseph Leones, has been proven hit Romeo. beyond reasonable doubt. The cause of death was established through the Ruling: death certificate and the testimony of the The court reverses the judgment of conviction and municipal health officer, who examined the body acquits Joseph Leones of the crime charged. and found a gunshot wound as the cause of death. Eugenio acted with treachery because he invited Ratio: Romeo to have a drink, then suddenly shot him The court finds that the evidence presented by the from behind without any ceremony. The use of a prosecution is insufficient to establish the guilt of gun and the victim's unarmed state support the the accused beyond reasonable doubt. The court finding of treachery. notes that the complainant's version of events is Eugenio is not entitled to the mitigating inconsistent and contradictory. Her claim of feeling circumstance of drunkenness because his claim of pain when Joseph inserted his private parts into being drunk is self-serving and uncorroborated. He hers, despite being unconscious at that time, is was still able to remember details and flee from deemed incredible. Additionally, the court the authorities, indicating that his mental capacity considers the immoral behavior and conduct of the was not impaired. complainant, as testified by witnesses, which Eugenio is entitled to the mitigating circumstance raises doubts about her credibility. The court of voluntary surrender because he voluntarily emphasizes that convictions for rape should not be surrendered to the authorities upon the advice of sustained without clear and convincing proof of his parents. guilt. It also highlights the need to exercise caution Eugenio cannot be credited with the mitigating and not accept the uncorroborated testimony of circumstance of a voluntary plea of guilty because the injured woman without suspicion. Based on he offered to plead guilty to a lesser offense only after some evidence of the prosecution had been Feria appealed the decision to the Court of presented. Appeals, which affirmed the trial court's decision Eugenio is not entitled to the privileged mitigating but modified the order by ordering the transfer of circumstance because he did not meet the Feria to the Bureau of Corrections in Muntinlupa requirements for a voluntary plea of guilty. City without the submission of the requirements. Feria's motion for reconsideration was denied, FERIA VS CA (G.R. No. 122954) leading him to file a petition for certiorari with the Facts: Supreme Court. Norberto Feria was convicted of the crime of The Supreme Court found sufficient evidence to Robbery with Homicide and had been under establish Feria's conviction based on the available detention since May 21, 1981. records and the hearing conducted by the trial Feria sought to be transferred from Manila City Jail court. to the Bureau of Corrections in Muntinlupa City, The court noted that Feria had made admissions but the transfer could not be done because the regarding his conviction for the crime of Robbery records of his case, including the copy of the with Homicide. judgment, were missing. The court ruled that the mere loss or destruction Issue: of the records does not invalidate the judgment or Whether Feria's continued detention without a the commitment, and therefore, Feria's continued valid judgment violates his constitutional rights. detention was justified. The court explained that the proper remedy in this case would be the reconstitution of the judgment of the case. Ruling: It emphasized that reconstitution is the duty of Feria's continued detention is justified, and the both the prosecution and the defense. proper remedy is the reconstitution of the missing The court also noted that the records of another records. case for Illegal Possession of Firearms, which arose Ratio: from the same incident as the Robbery with The Supreme Court found sufficient evidence to Homicide case, could be of assistance in the establish Feria's conviction, which serves as the reconstitution process. legal basis for his detention. In conclusion, the Supreme Court denied Feria's The loss or destruction of the records does not petition for habeas corpus and affirmed the invalidate the judgment or the commitment. decision of the Court of Appeals. The reconstitution of the judgment is the duty of The court ruled that Feria's continued detention both the prosecution and the defense. was justified, and the proper remedy would be the The records of another case for Illegal Possession reconstitution of the missing records. of Firearms, which arose from the same incident as the Robbery with Homicide case, could be of TESTIMONY OR DEPOSITION AT A FORMER PROCEEDING: assistance in the reconstitution process. DE LEON VS PEOPLE (G.R. No. 108522) Detailed Digest: Facts: Norberto Feria had been under detention since Lawyer Gerardo A. del Mundo filed a petition for May 21, 1981, after being convicted of Robbery review to reverse a decision in an ejectment case with Homicide for the hold-up and killing of a and declare a writ of execution as null and void. United States Peace Corps Volunteer. The case originated from a lease contract between Feria sought to be transferred from Manila City Jail del Mundo and the spouses Carlos and Alejandra to the Bureau of Corrections in Muntinlupa City, Nava, who owned a house and lot in Quezon City. but the transfer could not be done because the Del Mundo failed to exercise his option to records of his case, including the copy of the purchase the property and instead sent the Navas judgment, were missing. a Deed of Sale with Assignment of Mortgage, Feria filed a Petition for the Issuance of a Writ of which they later revoked due to del Mundo's Habeas Corpus with the Supreme Court, arguing failure to fulfill his promises. that his continued detention without a valid The Navas filed an unlawful detainer case against judgment violated his constitutional right to due del Mundo, which resulted in a decision ordering process. him to vacate the premises. The Supreme Court ordered the lower court to Del Mundo appealed the decision to the Regional conduct proper hearings on the case. Trial Court, but the court affirmed the decision The Regional Trial Court of Manila dismissed the with modifications. case, stating that the mere loss of the records does Del Mundo also filed a separate declaratory relief not invalidate the judgment or authorize the case, which was dismissed by the trial court. release of the prisoner. The Court of Appeals affirmed the dismissal, and The court ruled that the proper remedy would be del Mundo filed a petition for certiorari to the reconstitution of the records, which should be challenge the decision. filed with the court that rendered the decision. Issue: Whether the petition for certiorari is the proper Nelly Lim and Juan Sim are lawfully married to remedy to correct errors in judgments. each other. Ruling: Juan Sim filed a petition for annulment of their The Supreme Court denied del Mundo's petition, marriage on the grounds that Nelly Lim has been ruling that certiorari is not the proper remedy to suffering from schizophrenia before, during, and correct errors in judgments. after their marriage. The court also held that the issue of possession During the trial, Juan Sim's counsel announced can be resolved in an ejectment proceeding that they would present Dr. Acampado as a without deciding the issue of ownership. witness, who had examined and diagnosed Nelly The court found no basis to review the factual Lim with schizophrenia. conclusions of the lower courts and reprimanded Nelly Lim's counsel opposed the testimony, del Mundo for employing delaying tactics in the claiming that it violated the physician-patient case. privilege. The court affirmed the decision of the Court of A subpoena was issued for Dr. Acampado to testify Appeals and ordered del Mundo to pay treble despite the objection. costs. Nelly Lim's counsel filed a motion to quash the Ratio: subpoena, but it was denied by the trial court. The Supreme Court ruled that certiorari is not the Dr. Acampado then testified as an expert witness, proper remedy to correct errors in judgments. not as an attending physician of Nelly Lim. Certiorari is a special civil action that can only be Issue: availed of when there is no appeal or any other Whether the testimony of Dr. Acampado violates plain, speedy, and adequate remedy in the the physician-patient privilege. ordinary course of law. In this case, del Mundo had Ruling: the option to appeal the decision of the Regional The testimony of Dr. Acampado does not violate Trial Court, but instead chose to file a petition for the physician-patient privilege. certiorari. The court emphasized that certiorari is Ratio: not a substitute for an appeal and should not be The physician-patient privilege is intended to used as a means to correct errors in judgments. protect the patient and facilitate full and The court also held that the issue of possession confidential disclosure to the physician. can be resolved in an ejectment proceeding The privilege may be waived if no timely objection without deciding the issue of ownership. In an is made to the physician's testimony. ejectment case, the only issue to be resolved is the Requisites for claiming the privilege include that right to physical possession of the property. The the information was acquired by the physician court does not delve into the issue of ownership, while attending to the patient in a professional as it is a separate matter that should be resolved in capacity and that the information was necessary a separate proceeding. In this case, the lower for the physician to act in that capacity. courts correctly decided the issue of possession Only disclosures made to enable the physician to without delving into the issue of ownership. safely and effectively treat the patient are covered The court found no basis to review the factual by the privilege. conclusions of the lower courts. The Supreme Court's Argument: Court is not a trier of facts and generally defers to Dr. Acampado's testimony does not violate the the factual findings of the lower courts, unless privilege because she was presented as an expert there is a clear showing of grave abuse of witness and did not disclose any information discretion. In this case, del Mundo failed to obtained from Nelly Lim during her professional present any compelling reason to warrant a review capacity as a physician. of the factual conclusions made by the lower The interviews between Dr. Acampado and Nelly courts. The court found no grave abuse of Lim were conducted in the presence of a third discretion in their decisions. party, which may remove the information from the The court reprimanded del Mundo for employing privilege. delaying tactics in the case. Del Mundo filed a Nelly Lim's counsel did not object to any questions separate declaratory relief case, which was asked of Dr. Acampado during her testimony, dismissed by the trial court. This was seen as a which amounts to a waiver of the privilege. tactic to delay the resolution of the ejectment Conclusion: case. The court emphasized that litigants should The testimony of Dr. Acampado does not violate not abuse the judicial process by filing unnecessary the physician-patient privilege. and dilatory actions. As a result, the court ordered The requisites for claiming the privilege were not del Mundo to pay treble costs as a penalty for his met. actions. The information disclosed by Dr. Acampado did not blacken Nelly Lim's reputation. OPINION RULE: LIM VS CA (G.R. No. 91114) The petition is denied and the decision of the Facts: Court of Appeals is upheld. In rape cases, the important consideration is not the emission of semen but the penetration of the female genitalia by the male organ. The absence of PEOPLE VS GALLENO (G.R. No. 123546) spermatozoa in the victim's vagina does not Facts: negate the conclusion that it was the accused's The case involves the sexual abuse of a five-year- penis that was inserted. The fact that the victim old child named Evelyn Obligar Garganera. The experienced pain and profuse bleeding supports accused, Joeral Galleno, was charged with the the conclusion of penetration. crime of statutory rape. The incident occurred on August 16, 1994, at Brgy. Balighot, Maayon, Capiz. OPINION OF EXPERT WITNESS: CEBU SHIPYARD AND Accused-appellant entered the house of Evelyn ENGINEERING WORKS, INC. VS WILLIAM LINES, INC. (G.R. without permission and had carnal knowledge of No. 132607) her, causing a vaginal laceration that resulted in Facts: continuous bleeding and her admission to the The incident occurred on February 16, 1991, when hospital for five days. the M/V Manila City, owned by William Lines, Inc., Issue: caught fire and sank while undergoing repairs at The main issue in the case is whether or not the premises of Cebu Shipyard and Engineering accused-appellant committed the crime of Works, Inc. (CSEW). statutory rape. The vessel was insured with Prudential Guarantee Ruling: and Assurance Company, Inc. for P45 million. The trial court found accused-appellant guilty William Lines, Inc. sued CSEW for damages and beyond reasonable doubt of statutory rape and included Prudential as a co-plaintiff after sentenced him to suffer the death penalty. The Prudential paid the value of the hull and Supreme Court, in its automatic review of the case, machinery insurance on the M/V Manila City. affirmed the trial court's decision. The trial court ruled in favor of William Lines, Inc. Ratio: and Prudential, and CSEW appealed to the Court of Conclusions and opinions of witnesses are received Appeals, which affirmed the decision. in many cases, not just expert testimony, if it aids CSEW then filed a petition for review with the the court in reaching a judgment. In this case, the Supreme Court. trial court arrived at its conclusions not only with Issue: the aid of expert testimony but also the testimony Whether CSEW was negligent and liable for the of other prosecution witnesses, especially the loss of the M/V Manila City. victim herself. The fact that the experts Whether the doctrine of res ipsa loquitur should enumerated various possible causes of the victim's apply. laceration does not mean that the trial court's Ruling: inference is wrong. The Supreme Court ruled in favor of William Lines, Evidence must have a relation to the fact in issue Inc. and Prudential, upholding the findings of the as to induce belief in its existence or non- trial court and the Court of Appeals. existence. Relevancy is determinable by the rules The Court applied the doctrine of res ipsa loquitur of logic and human experience. The determination and found that all the conditions for its application of whether particular evidence is relevant rests were present. largely at the discretion of the court, which must The Court found direct evidence to prove that the be exercised according to the teachings of logic workers of CSEW were negligent in their duty of and everyday experience. exercising due diligence in the care of the vessel. Any objection involving a warrant of arrest or The Court rejected CSEW's claim to be a co- procedure in the acquisition of jurisdiction over assured under the insurance policy. the accused must be made before he enters his The Court ruled that the limitation of liability for plea, otherwise, the objection is deemed waived. negligence to One Million Pesos was unfair and The accused should question the validity of his inequitable. arrest before entering his plea in the trial court. If Ratio: he fails to do so, he is estopped from questioning The Court applied the doctrine of res ipsa loquitur, any defect in the manner of his arrest. which means "the thing speaks for itself," and A judge may properly intervene in the found that all the conditions for its application presentation of evidence to expedite and prevent were present. This means that the mere unnecessary waste of time and clarify obscure and occurrence of the incident itself raises a incomplete details after the witness has given presumption of negligence on the part of the direct testimony. However, undue interference defendant. may prevent the proper presentation of the cause The Court found direct evidence to prove that the or the ascertainment of truth. In this case, the trial workers of CSEW were negligent in their duty of court judge propounded questions for clarification exercising due diligence in the care of the vessel. purposes and not to build the case for one of the This evidence included the failure to provide parties. adequate fire-fighting equipment, failure to properly secure the vessel, and failure to take necessary precautions to prevent the fire from spreading. The Court rejected CSEW's claim to be a co- assured under the insurance policy, as the policy only named William Lines, Inc. as the assured. The Court emphasized that insurance contracts are strictly construed against the insurer and liberally in favor of the insured. The Court ruled that the limitation of liability for negligence to One Million Pesos was unfair and inequitable, considering the total loss suffered by William Lines, Inc. amounted to Forty Five Million Pesos. The Court held that the limitation of liability clause should not be enforced when it would result in an unjust and inequitable situation. In summary, the Supreme Court upheld the findings of negligence against CSEW, applied the doctrine of res ipsa loquitur, rejected CSEW's claim to be a co-assured under the insurance policy, and ruled that the limitation of liability for negligence was unfair and inequitable.