In People v. Roger Dela Cruz y Doe, the Supreme Court addressed the admissibility of statements made by a victim shortly after a startling event, even if not considered a dying declaration. The Court ruled that such statements could be admitted as part of res gestae, an exception to the hearsay rule, if they meet specific criteria. This decision clarifies the scope of admissible evidence in criminal proceedings and highlights the importance of spontaneous utterances made during or immediately after a crime.

A Cry for Justice: When Does a Dying Man’s Accusation Speak the Truth?

Roger Dela Cruz was accused of fatally stabbing Mark Lester Suarez. At trial, the prosecution presented testimony that, immediately after the stabbing, Suarez identified Dela Cruz as his attacker. While Suarez’s statement did not qualify as a dying declaration (a statement made by a person believing death is imminent) because there wasn’t sufficient evidence he believed he was about to die, the Supreme Court considered its admissibility under the principle of res gestae. This doctrine allows certain out-of-court statements related to a startling event to be admitted as evidence, based on the idea that people are less likely to lie while under the stress of such an event. The question before the court was whether Suarez’s identification of Dela Cruz fit within this exception.

The Court referenced its earlier decision in People v. Bautista, et al., emphasizing that the declarant’s belief of impending death, not its immediacy, is what renders a dying declaration admissible. However, the statement was found to qualify as part of the res gestae because it satisfied the three critical elements. First, the stabbing itself constituted a startling occurrence. Second, the statement was made immediately after the stabbing, before the victim had time to fabricate or contrive a false accusation. Third, the statement directly related to the startling event, specifically identifying the person responsible for the attack. These factors combined made Suarez’s statement admissible as evidence against Dela Cruz, regardless of whether it met the requirements for a dying declaration.

The requisites for a statement to be considered part of res gestae are: (1) a principal act, the res gestae, is a startling occurrence; (2) the statements were made before the declarant had time to contrive or devise; and (3) the statements must concern the occurrence in question and its immediately attending circumstances, as stipulated in People v. Cantonjos. The Court emphasized that witness credibility is primarily a matter for the trial court, and its findings are generally respected on appeal unless clear errors are shown. The Court found no basis to overturn the trial court’s assessment of the credibility of the prosecution witnesses who testified about Suarez’s statement.

Dela Cruz offered a defense of denial and alibi, claiming he was in Manila and Cavite seeking work around the time of the stabbing. However, the Court noted that denial is a weak defense, and alibi is viewed with suspicion, as it’s easily fabricated. The prosecution witness testified that he saw the accused fleeing the scene. This testimony was given greater weight because it directly contradicted Dela Cruz’s alibi. The Court also pointed to Dela Cruz’s flight from the scene and his subsequent arrest months after the warrant was issued as evidence of guilt.

While the trial court convicted Dela Cruz of murder, the Supreme Court disagreed, finding that the prosecution failed to prove treachery. Treachery requires a sudden and unexpected attack that deprives the victim of the ability to defend themselves. Because the prosecution witnesses did not directly observe the stabbing, they could not establish that the attack was treacherous. Consequently, the Court downgraded the conviction to homicide, which is defined as the unlawful killing of another person without any qualifying circumstances. The penalty for homicide under Article 249 of the Revised Penal Code is reclusion temporal.

In modifying the decision, the Court applied the Indeterminate Sentence Law, sentencing Dela Cruz to an indeterminate penalty ranging from eight (8) years and one (1) day of prision mayor, as minimum, to fourteen (14) years, eight (8) months and one (1) day of reclusion temporal, as maximum. The Court affirmed the award of civil indemnity and moral damages, but also awarded temperate damages of P25,000.00 in lieu of the lesser proven actual damages. This reflects a legal recognition that even when precise monetary losses are difficult to quantify, the victim’s family deserves compensation for their suffering.

FAQs

What is “res gestae”?	“Res gestae” refers to spontaneous statements made during or immediately after a startling event, which are admissible as evidence despite being hearsay. These statements are considered reliable because they are made under the stress of the event, reducing the likelihood of fabrication.
What are the elements for a statement to be admitted as part of “res gestae”?	The requirements are: (1) a startling event, (2) statements made before the declarant has time to fabricate, and (3) the statements concern the event and its circumstances. These elements ensure the statement’s reliability and relevance to the case.
What is the difference between a “dying declaration” and “res gestae”?	A dying declaration is made by a person believing their death is imminent and concerns the cause of their death, while res gestae statements are made during or immediately after a startling event. The key difference lies in the declarant’s awareness of impending death.
Why was Dela Cruz’s conviction reduced from Murder to Homicide?	The Supreme Court found that the prosecution failed to prove the qualifying circumstance of treachery beyond a reasonable doubt. Since the attack wasn’t proven to be sudden and unexpected, the charge was reduced to homicide.
What is the penalty for Homicide under the Revised Penal Code?	Homicide is punished by reclusion temporal, which ranges from twelve years and one day to twenty years of imprisonment. The specific duration depends on the presence of mitigating or aggravating circumstances.
What is the significance of “flight” in criminal cases?	Flight from the scene of a crime can be considered an indication of guilt. It suggests a guilty mind and consciousness of wrongdoing on the part of the accused.
What is the Indeterminate Sentence Law?	The Indeterminate Sentence Law requires courts to impose a minimum and maximum term of imprisonment, allowing parole boards to determine when an offender is ready for release. This law promotes rehabilitation and individualized justice.
Why did the court award temperate damages?	The court awarded temperate damages because the proven actual damages were less than P25,000.00. It deemed it fair to award the standard P25,000.00, especially since actual damages are hard to prove

This case underscores the importance of understanding exceptions to the hearsay rule and the weight given to spontaneous statements in criminal proceedings. The Supreme Court’s careful analysis of the facts and applicable laws ensured a just outcome, considering both the victim’s rights and the accused’s right to a fair trial.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People v. Dela Cruz, G.R. No. 152176, October 01, 2003