CASE DIGEST : BENJIE LAGAO Y GARCIA v. PEOPLE GR 217721 GAERLAN

[ GR No. 217721, Sep 15, 2021 ]

BENJIE LAGAO Y GARCIA v. PEOPLE

FACTS : Benjie Lagao was charged with homicide for allegedly attacking and fatally injuring Anthony Nerida in Bauang, La Union, on February 20, 2008. Witnesses Ricardo de Guzman and Ryan Cruz testified that the victim told them Lagao struck him during an altercation, while the victim’s father confirmed the same account and testified about funeral expenses. Lagao denied the accusation, but the RTC convicted him, sentencing him to 8 years and 1 day to 12 years and 1 day imprisonment, with damages to the victim’s family. The Court of Appeals affirmed, ruling that the victim’s statements were admissible as part of the res gestae, linking Lagao to the crime. On appeal to the Supreme Court, Lagao argued that the testimonies were hearsay, lacked spontaneity, and that there was no proof beyond reasonable doubt of his guilt. The prosecution, however, maintained that the lower courts’ factual findings were sound, emphasizing that any inconsistencies were minor and that the victim’s statements were credible evidence.

ISSUE : WON the RTC erred in relying upon these testimonies as basis for his conviction

HELD : The Supreme Court ruled that this case falls under an exception allowing it to review factual issues since the findings of both the RTC and CA were manifestly mistaken. It reiterated that the accused is presumed innocent and must be convicted only when guilt is proven beyond reasonable doubt. The Court found inconsistencies between the death certificate, which cited natural causes, and the autopsy report, which attributed the death to head injury, placing the evidence in equipoise—thus favoring acquittal. It also ruled that the victim’s statements identifying the petitioner were inadmissible hearsay, as they did not qualify as either a dying declaration (since the victim was not aware of impending death) or res gestae (as the statements lacked spontaneity and were made hours later during casual drinking). Since no eyewitnesses directly linked the petitioner to the crime and the prosecution’s case relied solely on hearsay, the Court held that the prosecution failed to prove guilt beyond reasonable doubt, warranting the petitioner’s acquittal.