FERNANDO V. PEOPLE [G.R. No. 259589 July 29, 2025]

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FERNANDO V. PEOPLE

[G.R. No. 259589 July 29, 2025]

FIRST DIVISION, Rosario, J. 

 

New Trial; Newly Discovered Evidence; Witness Recantation; Affidavit of Recantation; Carnapping; Quantum of Evidence. 

 

As a general rule, a witness' recantation is not a sufficient ground for a new trial because affidavits of recantation are inherently unreliable and are often viewed with suspicion. However, a new trial may be granted where the recanting witness' testimony was indispensable to the judgment of conviction, there exist special circumstances casting serious doubt on the truthfulness of the original testimony, and no other independent evidence supports the conviction. In such exceptional cases, the interest of substantial justice outweighs the policy against reopening criminal judgments. 

 

Charlon Fernando was charged with Carnapping under Republic Act No. 6539 for allegedly taking, without the owner's knowledge and consent, a Honda XRM motorcycle owned by Francisco Combate in Olongapo City on October 28, 2013. The motorcycle was valued at ₱102,816.00. Charlon pleaded not guilty upon arraignment. 

During trial, the prosecution principally relied on the testimony of Darius Santos, who claimed that he saw Charlon pushing Francisco's motorcycle before mounting it and driving away. Two days later, Darius informed Francisco that he had seen the person who took the motorcycle. Based on Darius' description, Francisco identified Charlon as the culprit, after which Darius confirmed the identification. Francisco himself did not witness the actual taking of the motorcycle. 

Charlon denied the accusation and interposed the defense of alibi. He presented several witnesses who testified that he attended his cousin's birthday celebration on the evening of October 28, 2013 and remained there until midnight. The Regional Trial Court nevertheless found the prosecution evidence sufficient and convicted Charlon of Carnapping. The Court of Appeals affirmed the conviction in toto. 

After the Court of Appeals rendered its decision, Darius executed a Salaysay ng Pag-urong (Affidavit of Retraction). In the affidavit, he declared that he never actually saw Charlon take the motorcycle; that Francisco Combate and his aunt coached him regarding what he should tell both the police and the court; that he was still a minor when he testified and was easily influenced; that he falsely identified Charlon because he was instructed to do so; and that he was executing the affidavit voluntarily to correct his previous false testimony. Based on this affidavit, Charlon moved for a new trial. The Court of Appeals denied the motion, holding that recantation alone is generally insufficient to warrant a new trial. Charlon thereafter elevated the case to the Supreme Court. 

 

Issue No. 1: Whether or not the Affidavit of Retraction executed by the prosecution's principal eyewitness justified the grant of a new trial.

YES. The Supreme Court held that although affidavits of recantation are generally viewed with suspicion and ordinarily do not constitute newly discovered evidence, this case falls within the recognized exceptions. 

The Court reiterated that for a witness' recantation to justify a new trial, three requisites must concur:

1. The testimony of the recanting witness during trial must have been essential to the judgment of conviction such that its elimination would lead to a different conclusion;
2. Special circumstances must exist which, together with the recantation, cast doubt on the truthfulness of the original testimony; and
3. No other evidence independently sustains the judgment of conviction aside from the testimony of the recanting witness. 

Applying these requisites, the Court found that Darius' testimony constituted the sole direct evidence identifying Charlon as the perpetrator. Without such testimony, the prosecution had no eyewitness linking Charlon to the offense. Consequently, his testimony was indispensable to the conviction. 

 

Issue No. 2: Whether or not the conviction could still be sustained despite the recantation.

NO. The Court ruled that the remaining prosecution evidence was insufficient to sustain the conviction independently of Darius' testimony. Francisco merely testified regarding his ownership of the motorcycle and the circumstances surrounding its disappearance. He did not witness the taking and relied entirely on Darius' account to identify the accused. Thus, once serious doubt was cast upon Darius' testimony, there remained no independent evidence directly proving Charlon's guilt beyond reasonable doubt. 

The Court emphasized that because the offense charged carried a severe penalty involving deprivation of liberty, the interest of justice demanded that the accused be afforded a new trial rather than risk sustaining a conviction resting on doubtful evidence.

 

 

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