REYNANTE TADEJA v. PEOPLE

FACTS:

The incident occurred during the annual fiesta of Barangay Talabaan, Mamburao, Occidental Mindoro. Maria Elena Bernardo Almaria and Jacinta del Fierro witnessed Ruben Bernardo being hacked to death by the Tadeja brothers and their cousin Plaridel Tadeja. The witnesses claimed that Plaridel accidentally hit Reynante Tadeja while attempting to hack Ruben. Ruben was brought to the hospital after the incident.

On the other hand, the petitioners alleged that Ruben and his sons went to the barangay plaza after one of his sons was prevented from entering the dance hall. They claimed that Ruben was brandishing a knife and cursing at the crowd. The Bernardos challenged Reynante, and a fight ensued. The brothers testified that they were together at their mother's house during the incident.

Reynante was able to evade Ruben's first knife attack but was pursued by him. Russell and Robenson blocked Reynante's path, causing him to fall. The Bernardos then took turns attacking Reynante. Ruben stabbed him multiple times before running away. Reynante managed to return to the plaza and was taken to the hospital.

Based on Reynante's account, a report was sent to the police stating that Ruben chased and stabbed him. Criminal cases were filed against the Tadeja brothers and Plaridel. The trial court found them guilty of homicide and sentenced them to imprisonment. Russell and Robenson were acquitted of frustrated homicide. The accused appealed to the Court of Appeals, which affirmed the trial court's decision in one case.

The petitioners filed a motion for reconsideration, submitting missing transcripts of testimonies they believed could debunk the prosecution witnesses' testimonies. The Court of Appeals denied the motion, stating that the additional transcripts would not affect the positive testimonies of the prosecution witnesses. The petitioners then filed a petition for review with the Supreme Court, arguing that all pieces of evidence should have been considered. They questioned the credibility of the prosecution witnesses and argued that their non-flight should be considered as evidence of innocence. The Supreme Court affirmed the decision of the Court of Appeals, stating that the additional testimonies would not have altered the judgment of conviction by the trial court.

ISSUES:

  1. Whether the testimonies of Leticia, Regina, and Eduardo should have been given due weight in considering the totality of the evidence.

  2. Whether the defense of alibi put forward by Ferdinand, Ricky, and Ricardo was credible.

  3. Whether the second motion for reconsideration filed by petitioners should be considered as a prohibited pleading.

  4. Whether the motion to vacate judgment should be granted based on the grounds of newly discovered evidence and supervening event.

  5. Whether or not the case should be reopened to consider newly discovered evidence.

  6. Whether or not the confession of Plaridel meets the requirements of newly discovered evidence.

  7. Whether or not Plaridel's version in his extrajudicial confession qualifies as newly discovered evidence that warrants a new trial.

RULING:

  1. The testimonies of Leticia, Regina, and Eduardo would not have altered the judgment of conviction by the Regional Trial Court (RTC).

  2. The defense of alibi presented by Ferdinand, Ricky, and Ricardo was not physically impossible.

  3. The second motion for reconsideration filed by petitioners is considered a prohibited pleading.

  4. The motion to vacate judgment was denied based on lack of merit.

  5. The Supreme Court denied the motion to reopen the case for reception of further evidence in the trial court. The Court emphasized that pleas for the remand of a case for a new trial may only be entertained before a judgment of conviction becomes final. In this case, the judgment of conviction had already become final and executory. The Court also held that the confession of Plaridel does not meet the requirements of newly discovered evidence, as it could have been obtained during the trial and does not align with the other witness's testimony.

  6. The motion for a new trial to reopen the case for the reception of further evidence is denied. The Court held that Plaridel's version in his extrajudicial confession is not considered newly discovered evidence that can be a ground for a new trial.

PRINCIPLES:

  • The totality of the evidence should be considered in making a judgment.

  • Blood relationship may fortify credibility and make it unnatural for an aggrieved relative to falsely accuse a person other than the actual culprit.

  • The defense of alibi must be physically impossible for it to be credible.

  • A second motion for reconsideration is considered a prohibited pleading.

  • A motion to vacate judgment based on newly discovered evidence and supervening event may warrant a new trial.

  • Judgments or orders of courts should attain finality at some definite time fixed by law to avoid prolonging litigation.

  • A new trial may only be granted before a judgment of conviction becomes final.

  • Newly discovered evidence refers to evidence that (a) is discovered after trial; (b) could not have been discovered and produced at the trial even with reasonable diligence; (c) is material, not merely cumulative, corroborative, or impeaching; and (d) is of such weight that it would probably change the judgment if admitted.

  • Newly discovered evidence must be presented to the trial court before judgment becomes final and executory.

  • A motion for a new trial after the judgment of conviction has become final and executory is an exception and must be granted pro hac vice, which means it is applicable only for this one particular occasion.

  • Courts are bound to apply the rules they have laid down to facilitate their duty to dispense justice.