People vs Villarico

Doctrines:
identification of the accused in a criminal case need not always be by direct evidence from an
eye witness, for reliable circumstantial evidence can equally confirm it
part of the res gestae as an exception to the hearsay rule

Facts:
The victim Haide Cagatan was shot twice. the fatal wound that caused his death was that one
at back of his left shoulder which penetrated through his neck. the victims sister in law, his
mother , and his father all testified in court . Remedios(sister in law of the victim) said that she
saw the four accused aiming their firearms towards the direction of their kitchen, the victim was
there at that time cooking their food. She also said that one of the accused even pointed a gun
at her upon seeing her witnessing what they were about to do. His father also testified that he
saw the 4 accused near their kitchen after he heard several gunshots. the victim according to
his mother after the shooting incident managed to crawl to him saying that he was shot by
Berting, one of the accused. all of the accused in their defense presented different alibis saying
that they were all not at the scene of the crime when it happened. the RTC convicted the
accused of homicide but on appeal the CA raised it to murder. the 4 accused in this appeal
raised the issue that the their identity as the perpetrators of the crime was never established
with reasonable certainty because the prosecution failed to present direct evidence from an
eyewitness.
Issue:
are the pieces of evidence presented in this case enough to identify the accused in this case
though the prosecution failed to present an eyewitness positively identifying the 4 accused as
the perpetrator of the crime?
Ruling:
the Supreme court ruled in the affirmative. There are two types of positive identification. A
witness may identify a suspect or accused in a criminal case as the perpetrator of the crime as
an eyewitness to the very act of the commission of the crime. This constitutes direct evidence.
There may, however, be instances where, although a witness may not have actually seen the
very act of commission of a crime, he may still be able to positively identify a suspect or
accused as the perpetrator of a crime as for instance when the latter is the person or one of the
persons last seen with the victim immediately before and right after the commission of the
crime. This is the second type of positive identification, which forms part of circumstantial
evidence, which, when taken together with other pieces of evidence constituting an unbroken
chain, leads to only fair and reasonable conclusion, which is that the accused is the author of
the crime to the exclusion of all others. If the actual eyewitnesses are the only ones allowed to
possibly positively identify a suspect or accused to the exclusion of others, then nobody can
ever be convicted unless there is an eyewitness, because it is basic and elementary that there
can be no conviction until and unless an accused is positively identified. Such a proposition is
absolutely absurd.
in addition, the statement of the victim to his mother that he had just been shot by the
group of Berting uttered in the immediate aftermath of the shooting where he was the victim
was a true part of the res gestae. The statement was admissible against the accused as an
exception to the hearsay rule under Section 42, Rule 130 of the Rules of Court, which provides:
Section 42. Part of the res gestae. - Statements made by a person while a startling occurrence
is taking place or immediately prior or subsequent thereto with respect to the circumstances
thereof, may be given in evidence as part of the res gestae. So, also, statements accompanying
an equivocal act material to the issue, and giving it a legal significance, may be received as part
of the res gestae.

PNR vs Vizcara
Doctrine: It is the responsibility of the railroad company to use reasonable care to keep the
signal devices in working order. Failure to do so would be an indication of negligence

Facts:
this is a case for damages resulting from the death of the victims herein, following the collision
of a PNR train and a jeepney carrying them. When the incident happened there was no level
crossing installed at the railroad crossing, additionally, the Stop, Look and Listen signage was
poorly maintained. The Stop signage was already faded while the Listen signage was partly
blocked by another signboard. Private respondents argued that the proximate cause of the
incident was the negligence of PNR, PNR on the other hand argued that their train driver
exercised due diligence in operating the train and in monitoring its roadworthiness,
Issue:
is the PNR guilty of negligence in this case?
Ruling:
yes the PNR is negligent, hence they are liable for damages. The PNR fell short of the diligence
expected of it, taking into consideration the nature of its business, to forestall any untoward
incident. In particular, the petitioners failed to install safety railroad bars to prevent motorists
from crossing the tracks in order to give way to an approaching train. Aside from the absence of
a crossing bar, the Stop, Look and Listen signage installed in the area was poorly maintained,
hence, inadequate to alert the public of the impending danger. A reliable signaling device in
good condition, not just a dilapidated Stop, Look and Listen signage, is needed to give notice
to the public. It is the responsibility of the railroad company to use reasonable care to keep the
signal devices in working order. Failure to do so would be an indication of negligence.

Del Carmen Jr vs Bacoy
Doctrine: Res ipsa loquitur (the thing speaks for itself), a doctrine that creates a rebuttable
presumption of negligence on the part of the defendant in the absence of direct proof to the
contrary
Facts: private respondents heirs of the deceased victims of vehicular accident filed a case for
damages against petitioner herein del Carmen Jr, the registered owner of the vehicle. Allan
maglasang the one operating the vehicle at that time was convicted for reckless imprudence
resulting to multiple homicide. Del Carmen Jr argued that he cant be held liable for damages in
this case because he was in fact a victim as well, he claims that the victim was stolen by Allan
when the accident happened. however aside from such averment Del Carmen Jr failed to
present any reasonable, sufficient and logical explanation that the incident happened not
because of their want of care.
Issue: is del Carmen liable for damages in this case?
Held:
Del carmens own evidence casts doubt that the vehicle was indeed stolen. first the
carnapping case he filed against Allan was dismissed, secondly it was found out that Allan was
his employee as a conductor when it happened. the doctrine of res ipsa loquitur was used by
the court in stating that del Carmen is liable for damages.
Court stated that where the thing that caused the injury complained of is shown to be
under the management of the defendant or employees and the accident in the ordinary course
of things would not have happened if those managing it or those in control of it used proper care
it affords reasonable evidence, without requiring the presentation of any other direct proof,
because such creates a rebuttable presumption of negligence. in the absence of a sufficient
reasonable and logical explanation by the defendant that the incident happened not because of
their want of care, the defendant will be declared as negligent even without direct proof. all of
these elements were present in the case hence del Carmen was adjudged liable for damages
by virtue of the doctrine of res ipsa loquitur.

Alcantara vs Ponce
Doctrine: Privilege communication, documents submitted as part of a preliminary investigation
are considered privileged communication and cannot be used as a basis for a libel case.
Facts:
Ponce in a case for estafa he file against Alcantara accused the latter of defrauding him of his
shares in Iligan cement Corporation. such pronouncement was made by ponce in the course of
the preliminary investigation of the complaint for estafa, shortly after giving his sur-rejoinder
affidavit, submitted to the investigating prosecutor a newsletter

purporting to be a belated annex
to the affidavit. in connection to such affidavit filed by ponce to the investigating prosecutor,
Alcantara filed a case for libel against ponce, claiming that the statements therein were
defamatory.
Issue:
are documents submitted as part of a preliminary investigation considered privileged
communication and cannot be used as a basis for a libel case?
Ruling:
the supreme court stated that yes, documents submitted as part of a preliminary investigation
are considered privileged communication. such documents cant be used as evidence in
prosecuting a libel case. According to the Supreme Court, the newsletter had a privileged
character, even if Philippine laws do not categorically state that the doctrine of absolute privilege
extends to statements made in preliminary investigations.

People vs Rellota
Doctrine: Minor inconsistencies on the testimony of a victim of rape wont affect her credibility,
acts of lasciviousness vis a vis attempted rape.
Facts:
AAA a minor (12 years old) filed a case of 2 counts of rape and a case for attempted
rape against Rellota. she claimed that she was forcibly raped twice by Rellota on two different
occasions, on both instances Rellota inserted his penis to her private part. the third incident was
halted by AAAs resistance, she was able to escape, thereafter she told what had happened to
her sister, both of them went to the police. she relayed the 2 previous instances of rape and the
recently halted incident. subsequently the cases were filed against Rellota. Rellota alleged as
his defense that the testimony of AAA was flawed by several inconsistencies.
Issue:
are the inconsistencies pointed by Rellota sufficient to cause his acquittal?
Ruling:
court ruled that no. the said inconsistencies pointed out by Rellota were minor ones
which do not affect the credibility of AAA nor erase the fact that the latter was raped.
The inconsistencies are trivial and forgivable, since a victim of rape cannot possibly give an
exacting detail for each of the previous incidents, since these may just be but mere fragments
of a prolonged and continuing nightmare, a calvary she might even be struggling to forget

For his defense, appellant merely denied having raped AAA. However, denial, when
unsubstantiated by clear and convincing evidence, constitutes negative self-serving evidence
which deserves no greater evidentiary value than the testimony of a credible witness who
testified on affirmative matters.
In the present case, the records are devoid of any clear and convincing evidence that would
substantiate appellant's denial. In the same manner, appellant's claim that the filing of the
criminal charges against him was instigated by AAA's aunt because he failed to lend the latter
money is uncorroborated by any evidence. Thus, when there is no evidence to show any
improper motive on the part of the rape victim to testify falsely against the accused or to falsely
implicate him in the commission of a crime, the logical conclusion is that the testimony is worthy
of full faith and credence. He was convicted of two counts of rape in this case.
However the court just downgraded the third incident in this case as only act of
lasciviousness and not attempted rape, the court stated that Rellotas act of removing the towel
wrapped in the body of AAA, laying her on the sofa and kissing and touching her private parts
does not exactly demonstrate the intent of appellant to have carnal knowledge of AAA on that
particular date; thus, dismissing the mere opinion and speculation of AAA, based on her
testimony, that appellant wanted to rape her. Even so, the said acts should not be left
unpunished as the elements of the crime of acts of lasciviousness

Phil Carpet Manufacturing vs Tagyamen
Doctrine: stare decisis - when a court has laid down a principle of law as applicable to a certain
state of facts, it will adhere to that principle and apply it to all future cases in which the facts are
substantially the same, even though the parties may be different.

Where the facts are essentially
different, however, stare decisis does not apply, for a perfectly sound principle as applied to one
set of facts might be entirely inappropriate when a factual variant is introduced.
Facts:
PCMC retrenched several employees including private respondents herein due to business
losses. these employees filed a case for illegal dismissal, PMPC won the case with the Labor
arbiter and with the NLRC however upon appeal the CA reversed the nlrc decision, citing the
doctrine enunciated by the court in the Philcea case, the CA invoked the principle of stare
decisis to invalidate the retrenchment program made by PCMC.
Issue: can the court invoke the principle of stare decisis in ruling this case?
Ruling: yes. this case and the Philcea case involve the same period which is March to April
2004; the issuance of Memorandum to employees informing them of the implementation of the
cost reduction program, the implementation of the voluntary retirement program and
retrenchment program, except that this case involves different employees; the execution of
deeds of release, waiver, and quitclaim, and the acceptance of separation pay by the affected
employees.
The illegality of the basis of the implementation of both voluntary retirement and retrenchment
programs of petitioners had been thoroughly ruled upon by the Court in the Philcea case. It
discussed the requisites of both retrenchment and redundancy as authorized causes of
termination and that petitioners failed to substantiate them.
In ascertaining the bases of the termination of employees, it took into consideration
petitioners claim of business losses; the purchase of machinery and equipment after the
termination, the declaration of cash dividends to stockholders, the hiring of 100 new employees
after the retrenchment, and the authorization of full blast overtime work for six hours daily.
These, said the Court, are inconsistent with petitioners claim that there was a slump in the
demand for its products which compelled them to implement the termination programs. In
arriving at its conclusions, the Court took note of petitioners net sales, gross and net profits, as
well as net income. these circumstances were exactly the same as in the case at hand. thats
why in resolving the issue involved in this case, the court simply invoked the doctrine of stare
decisis.