Tadeja vs. People

A motion for new trial based on newly discovered evidence cannot be granted after the judgment of conviction has become final and executory; furthermore, an extrajudicial confession by a co-accused who participated in the trial but absconded thereafter does not qualify as newly discovered evidence as it could have been discovered earlier with reasonable diligence and is inconsistent with the accused's own testimony.

On May 3, 1994, during the annual fiesta of Barangay Talabaan, Mamburao, Occidental Mindoro, Ruben Bernardo was killed following an altercation at a public dance around midnight. The incident stemmed from a confrontation between Ruben Bernardo, who was reportedly drunk and brandishing a knife, and Reynante Tadeja, who was waiting for his children and sisters inside the dance hall. The killing resulted in the filing of homicide charges against Reynante and his brothers Ricky, Ricardo, and Ferdinand, together with their cousin Plaridel Tadeja, based on eyewitness testimonies of the victim's relatives who claimed they saw the accused jointly attack and hack Ruben to death.

• On May 3, 1994, during the fiesta of Barangay Talabaan, Mamburao, Occidental Mindoro, Ruben Bernardo was killed after a confrontation at a public dance around midnight.
• Prosecution witnesses Maria Elena Bernardo Almaria and Jacinta del Fierro (relatives of the victim) testified that they saw petitioners (Reynante, Ricky, Ricardo, Ferdinand Tadeja) and their cousin Plaridel Tadeja jointly hack Ruben to death, and that they stayed at the scene until Ruben was brought to the hospital.
• Reynante Tadeja claimed self-defense, alleging that Ruben chased and stabbed him in the right chest and left side when he lost his balance after being blocked by Ruben's sons, Russell and Robenson, and that he was brought to the hospital without seeing who killed Ruben.
• The other petitioners (Ricky, Ricardo, Ferdinand) claimed alibi, stating they were asleep at their mother's house about one kilometer away from the crime scene, reachable by foot in twenty minutes or by tricycle in five minutes.
• On July 15, 1994, an Information for homicide was filed against all five accused, docketed as Criminal Case No. Z-814.
• The RTC convicted all accused on July 15, 1997, finding conspiracy based on the eyewitness testimonies and sentencing them to imprisonment.
• The CA affirmed the conviction on March 8, 2000, rejecting the defense of alibi and finding no reason for the prosecution witnesses to falsely accuse the petitioners.
• The Supreme Court affirmed the CA Decision on July 21, 2006, and denied the motion for reconsideration with finality on October 23, 2006.
• On July 26, 2007, the judgment became final and executory upon entry in the Book of Entries of Judgments.
• On November 29, 2006, Plaridel Tadeja (who had absconded during the appeal) was arrested in Area 1, Talanay, Batasan Hills, Quezon City.
• Plaridel executed an extrajudicial confession with the assistance of counsel admitting that he alone killed Ruben by grabbing the knife and stabbing him, claiming he did so to aid Reynante who was being chased and attacked by Ruben.
• Plaridel stated that he did not see the other petitioners (Ricky, Ricardo, Ferdinand) at the scene, and that he only admitted the crime later because he felt afraid during the trial and thus absconded.
• Petitioners also attached a "Pinagsamang Salaysay" signed by 228 residents of Barangay Talabaan attesting to petitioners' innocence.

• The totality of evidence in the jointly tried cases (Criminal Case No. Z-814 for homicide and Z-815 for frustrated homicide) should have been considered, including testimonies of defense witnesses Leticia Bernardo, Regina Cortuna, and Eduardo Eraso which were allegedly missing from the records forwarded to the CA.
• The testimony of Regina Cortuna contradicted the prosecution witnesses' claim that they stayed at the scene until Ruben was brought to the hospital, as Regina testified they were with her at Lola Tinay's house that night.
• The prosecution witnesses' testimonies were incredible as they were given nearly a year after the incident and were from relatives of the victim who had no immediate written statements to aid recollection.
• Alibi should be given weight as it was the "plain and simple truth" under the circumstances, and their non-flight was a "logical and favorable consideration pointing to their innocence."
• Plaridel's extrajudicial confession constitutes newly discovered evidence that would probably change the judgment if admitted, as it proves petitioners' innocence and Plaridel's sole guilt.
• The Court should suspend its rules in the interest of substantial justice and reopen the case for a new trial based on this supervening event.
• The case of People v. Licayan supports the reopening of cases after finality based on newly discovered evidence.

• The Office of the Solicitor General manifested that it was not posing any objection to the reopening of the case.
• Sonia A. Bernardo, widow of Ruben, manifested her objection to the reopening of the case.
• (In earlier proceedings) The OSG argued that the trial court had discretion to believe or disbelieve witness testimonies, that blood relationship does not necessarily make witnesses biased, and that while flight is indicative of guilt, non-flight is not an indication of innocence.

• Procedural Issues: Whether the Supreme Court may grant a motion to reopen a case and conduct a new trial after the judgment of conviction has become final and executory.
• Substantive Issues: Whether the extrajudicial confession of a co-accused who participated in the trial but absconded thereafter qualifies as newly discovered evidence warranting a new trial under Section 1 of Rule 121 of the Rules of Court.

• Procedural: The motion to reopen the case is denied. Under Section 1 of Rule 121 of the Rules of Court, a new trial may only be granted "at any time before a judgment of conviction becomes final." Since the judgment became final and executory on July 26, 2007, the Court can no longer entertain motions for new trial. Fundamental considerations of public policy and sound practice necessitate that judgments attain finality at some definite time fixed by law; otherwise, there would be no end to litigation. The Court distinguished its ruling in People v. Licayan as having been granted pro hac vice (for this one particular occasion) and therefore cannot be relied upon as precedent to govern other cases.
• Substantive: Plaridel's extrajudicial confession does not qualify as newly discovered evidence. The requisites for newly discovered evidence are: (a) discovered after trial; (b) could not have been discovered and produced at the trial even with the exercise of reasonable diligence; (c) material, not merely cumulative, corroborative or impeaching; and (d) of such weight that it would probably change the judgment if admitted. The most important requisite is that the evidence could not have been discovered and produced at the trial even with reasonable diligence. Plaridel participated in the trial before the RTC and even gave testimony as to his defense; he only absconded after conviction by the trial court. Thus, his confession could have been obtained during the trial. Moreover, Plaridel's confession is inconsistent with Reynante's narration of events (Reynante claimed Ruben ran away after stabbing him, while Plaridel claimed he stabbed Ruben while Reynante was being transported to the hospital, which would make it impossible for Reynante to have seen Ruben 15 meters away holding a knife). The Court concluded that the cousins chose not to tell the truth during trial. The matter was referred to the President through the Secretary of Justice for possible grant of executive clemency.

• Finality of Judgments — Judicial decisions must attain finality at a definite time fixed by law to end litigation and ensure stability in the legal system. Once a judgment becomes final and executory, it can no longer be disturbed or modified through a motion for new trial.
• Newly Discovered Evidence — Under Rule 121, Section 1, newly discovered evidence must meet four requisites: (1) discovered after trial; (2) could not have been discovered and produced at the trial with reasonable diligence; (3) material and not merely cumulative, corroborative, or impeaching; and (4) of such weight that it would probably change the judgment. The most critical element is the exercise of reasonable diligence in discovering the evidence during trial.
• Pro Hac Vice — A ruling expressly qualified as pro hac vice (for this one particular occasion) cannot be relied upon as precedent to govern other cases. It is an exception to general rules made for specific circumstances and does not establish binding legal doctrine.
• Blood Relationship as Fortifying Credibility — The relationship of witnesses to the victim does not necessarily impair credibility; rather, it may even fortify it, as it would be unnatural for an aggrieved relative to falsely accuse someone other than the actual culprit.
• Alibi — For alibi to prosper, the accused must prove that it was physically impossible for them to be at the scene of the crime at the time of its commission. Proximity to the crime scene (such as being only one kilometer away) defeats the defense of alibi.

• "Fundamental considerations of public policy and sound practice necessitate that, at the risk of occasional errors, the judgment or orders of courts should attain finality at some definite time fixed by law. Otherwise, there would be no end to litigation."
• "Newly discovered evidence refers to that which (a) is discovered after trial; (b) could not have been discovered and produced at the trial even with the exercise of 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."
• "The most important requisite is that the evidence could not have been discovered and produced at the trial even with reasonable diligence; hence, the term 'newly discovered.'"
• "A ruling expressly qualified as such [pro hac vice] cannot be relied upon as a precedent to govern other cases."

• People v. Licayan — Cited by petitioners as precedent for reopening a case after finality based on newly discovered evidence. The Court distinguished this case, noting it was granted pro hac vice and thus not binding precedent.
• So v. CA — Cited for the principle that judgments must attain finality to prevent endless litigation.
• People v. Judavar — Cited for the definition and requisites of newly discovered evidence.
• Partido ng Manggagawa v. COMELEC — Cited for the definition of pro hac vice as a ruling for one particular occasion that cannot serve as precedent.

• Section 1 of Rule 121 of the Rules of Court — Provides that a new trial may be granted at any time before a judgment of conviction becomes final, establishing the time limit for filing motions for new trial.
• Rule 45 of the Rules of Court — The procedural basis for the petition for review filed by petitioners to the Supreme Court.