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PEOPLE v. RENE MAMALIAS Y FIEL

FACTS:

Accused Rene Mamalias was convicted of murder and frustrated murder for the death of Francisco de Vera and the gunshot wound inflicted on Alexander Bunag. The crimes were allegedly committed on August 9, 1992, in the City of Manila. Accused pleaded not guilty, and his co-accused remained at large. The prosecution presented two witnesses, police investigator SPO3 Manuel Liberato and Dr. Remigio Rivera. SPO3 Liberato testified that the accused was arrested on January 4, 1993, and a relative of the murder victim brought an alleged eyewitness named Epifanio Raymundo to the police headquarters. Raymundo claimed to have seen the accused and his co-accused shoot De Vera and injure Bunag. SPO3 Liberato also prepared reports pertaining to the cases. Dr. Rivera testified that he treated Bunag's gunshot wound. The prosecution rested its case as they could not locate additional witnesses. The defense presented accused Mamalias as a witness. He denied any knowledge of the crimes and claimed he was in his house during the incident. Mamalias was arrested without a warrant and not assisted by counsel during his custodial investigation. The trial court found Mamalias guilty based on the evidence presented by the prosecution and sentenced him to reclusion perpetua for murder and frustrated murder.

ISSUES:

  1. Whether the Court has jurisdiction to determine the guilt or innocence of the accused-appellant considering his unknown whereabouts and evasion of custody.

  2. Whether the appeal should be dismissed due to the appellant escaping from custody or jumping bail.

  3. Whether the guilt of the accused-appellant was established beyond reasonable doubt.

  4. Whether or not the evidence presented by the prosecution is sufficient to prove the guilt of the accused beyond reasonable doubt.

  5. Whether or not the accused should be acquitted based on the weakness of the prosecution's evidence.

RULING:

  1. The Court may exercise jurisdiction over the appeal despite the evasion of custody by the accused-appellant. Although the general rule is that an escapee loses his standing in court and waives any right to seek relief, the Court has discretion to dismiss an appeal in exceptional cases. In this case, the Court chooses to proceed with the appeal.

  2. The Court held that the appeal should not be dismissed. Dismissing the appeal at this stage would result in injustice as it would benefit the accused-appellant. The Court resolved to continue exercising jurisdiction over the case to prevent a mockery of justice. However, the acquittal of the accused-appellant in one of the cases cannot be reviewed due to the rule on double jeopardy.

  3. The Court found that the guilt of the accused-appellant was not established beyond reasonable doubt. The trial court relied on hearsay evidence, particularly the testimony of a witness who had no personal knowledge of the facts surrounding the incident and the sworn statement of another witness who did not appear in court to affirm its content. Convicting the accused-appellant based on hearsay evidence would violate his constitutional right to confront and cross-examine witnesses. Suspicion and notoriety, without more, are not sufficient to establish guilt.

  4. The accused is acquitted of the crimes charged due to reasonable doubt. The decision of the Regional Trial Court is reversed and set aside.

PRINCIPLES:

  • An escapee loses his standing in court and waives any right to seek relief.

  • The Court has discretion to dismiss an appeal when the appellant escapes custody, but may choose to proceed with the appeal in exceptional cases.

  • The Court has the discretion to dismiss an appeal if the appellant escapes from custody or jumps bail.

  • Rules of procedure should be interpreted to serve the objective of rendering justice and not to frustrate the rendition of a just decision.

  • The presumption of innocence cannot be overcome by suspicion or conjecture. Proof beyond reasonable doubt of every fact essential to constitute the offense must be clearly established by the prosecution.

  • Hearsay evidence, when the source of the evidence does not testify in court, violates the accused's constitutional right to confront and cross-examine witnesses. A conviction based on such evidence is a nullity and the court that rendered it acted without jurisdiction.

  • Notoriety without more is not sufficient evidence to convict.

  • The prosecution has the burden of proving the guilt of the accused beyond reasonable doubt.

  • Conviction must be based on the strength of the prosecution's evidence, not on the weakness of the defense.

  • When the evidence for the prosecution is not enough to sustain a conviction, the accused must be absolved and released.