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People Vs Mamalias

Rene Mamalias y Feil was convicted of murder and frustrated murder based solely on hearsay evidence presented at trial. The Supreme Court overturned his conviction, finding that the prosecution failed to prove his guilt beyond a reasonable doubt as required by the Constitution. The two witnesses presented by the prosecution had no personal knowledge of the shooting incident and their testimony was based entirely on hearsay. A conviction based solely on hearsay evidence violates the accused's constitutional right to confront witnesses against him. Suspicion and notoriety are not evidence and cannot be the basis for a criminal conviction.

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Prudencio Ruiz Agacita
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201 views2 pages

People Vs Mamalias

Rene Mamalias y Feil was convicted of murder and frustrated murder based solely on hearsay evidence presented at trial. The Supreme Court overturned his conviction, finding that the prosecution failed to prove his guilt beyond a reasonable doubt as required by the Constitution. The two witnesses presented by the prosecution had no personal knowledge of the shooting incident and their testimony was based entirely on hearsay. A conviction based solely on hearsay evidence violates the accused's constitutional right to confront witnesses against him. Suspicion and notoriety are not evidence and cannot be the basis for a criminal conviction.

Uploaded by

Prudencio Ruiz Agacita
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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PEOPLE OF THE PHILIPPINES vs.

RENE MAMALIAS Y FIEL

FACTS:
Accused Rene Mamalias y Feil was convicted of murder and frustrated murder, for the death of Francisco
de Vera y Del Valle, and the gunshot wound inflicted on Alexander Bunag.

During the trial, the prosecution presented only two (2) witnesses, namely police investigator SPO3
Manuel Liberato of the Western Police District Command, who took the Affidavit of Epifanio
Raymundo, the alleged eyewitness of the shooting incident and Dr. Remigio Rivera, a resident physician
at Mary Johnston Hospital in Tondo, Manila, who testified that he treated the gunshot wounds of
Alexander Bunag.

He appealed, seeking his acquittal on the ground that the trial court convicted him purely on the basis of
hearsay evidence. However during the pendency of his appeal. He escaped, no longer in the custody of
the law and cannot be located.

In a Manifestation and Motion, the solicitor General recommended the acquittal of the accused-appellant
as his conviction was based on hearsay evidence.

ISSUE:

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

HELD:

NO. The Constitution  mandates that in all criminal prosecutions, the accused shall be presumed innocent
until the contrary is proved. To overcome the presumption of innocence, proof beyond reasonable doubt
of every fact essential to constitute the offense with which the accused is charged must be clearly
established by the prosecution.

In the case at bar, the trial court merely relied on hearsay evidence, particularly on the testimony of SPO3
Liberato and the sworn statement of Epifanio Raymundo who did not testify in the trial court.

The records clearly show that prosecution witness SPO3 Liberato has no personal knowledge of the facts
surrounding the shooting incident. The Progress Report and the Booking and Arrest Report he prepared
were based on information related to him by Epifanio Raymundo almost five (5) months after the crimes
were committed. In fact, contrary to the factual finding of the trial court that SPO3 Liberato went to
the locus criminis shortly after the shooting incident, the records show that it was PO3 Edgardo E. Ko
who was dispatched by the WPD Command to investigate the case. For unknown reason, PO3 Ko was not
called to the witness stand. The records also show that SPO3 Liberato was not even a member of the team
of policemen that apprehend the accused-appellant on January 4, 1993. He testified that the accused-
appellant was turned over to him only on January 6, 1993, and he did not know how the accused-
appellant was apprehended. He was also not aware whether a warrant of arrest had been issued against the
accused-appellant. Clearly, his knowledge of the circumstances surrounding the shooting incident was
limited to the matters relayed to him by his co-policemen and the alleged eyewitness, hence, hearsay.

In the same vein, the sworn statement of Epifanio Raymundo is merely hearsay evidence as he did not
personally appear in court to affirm its content. Its probative value, if any, is little.
We have held that in criminal cases, the admission of hearsay evidence would be a violation of the
constitutional provision that the accused shall enjoy the right to confront the witnesses testifying against
him and to cross-examine them. 

A conviction based alone on proof that violates the constitutional right of an accused is a nullity and the
court that rendered it acted without jurisdiction in its rendition. Such a judgment cannot be given any
effect whatsoever especially on the liberty of an individual.

Apparently, the trial court was swayed to convict the accused-appellant because he was suspected by the
police as a member of the dreaded "Robin Padilla gang", that was allegedly involved in a series of bank
robberies, murders and other offenses in Manila. Be that as it may, suspicion is never synonymous to
proof and notoriety without more is not evidence and cannot convict.

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