In People v. Dejillo, the Supreme Court affirmed the conviction of Dante Dejillo and Gervacio Hoyle, Jr. for murder, emphasizing the probative value of a victim’s dying declaration and consistent eyewitness testimony. The Court underscored that a dying declaration, made under the consciousness of impending death, holds significant weight when corroborated by other evidence. This case clarifies the standards for admissibility of dying declarations and reaffirms the importance of eyewitness accounts in criminal prosecutions, ensuring justice for victims of violent crimes.

Justice Whispered from the Brink: How a Dying Declaration Sealed a Murder Conviction

The case of People v. Dante Dejillo and Gervacio “Dongkoy” Hoyle, Jr. revolves around the murder of Aurelio “Boy” Basalo, a 22-year-old Sangguniang Kabataan (SK) Kagawad. Aurelio was fatally stabbed in Barangay Bugang, San Miguel, Bohol. Initially, Romeo Puracan was identified as the suspect, but Aurelio’s mother, Germana Basalo, suspected foul play and requested a murder investigation against Dejillo and Hoyle. The ensuing trial hinged on the admissibility of Aurelio’s dying declaration and the credibility of eyewitness testimony. The legal question before the court was whether the evidence presented, including the dying declaration, was sufficient to prove beyond reasonable doubt that Dejillo and Hoyle were responsible for Aurelio’s death.

The prosecution’s case rested heavily on the dying declaration of Aurelio, who, moments before his death, identified Dante Dejillo as the one who stabbed him while Gervacio Hoyle held him. A dying declaration is an exception to the hearsay rule, admissible as evidence if it meets specific requisites. As the Supreme Court reiterated, such a declaration must concern the crime and the circumstances of the declarant’s death, be made under a consciousness of impending death, come from a competent witness, and be offered in a case for homicide, murder, or parricide where the declarant is the victim. In this case, the RTC found that Aurelio’s statement met all these criteria.

The importance of the dying declaration is enshrined in jurisprudence, as noted in People v. Garma, 271 SCRA 517, 1997:

One of the most reliable pieces of evidence for convicting a person is the dying declaration of the victim. Courts accord credibility of the highest order to such declarations on the truism that no man conscious of his impending death will still resort to falsehood.

Building on this principle, the RTC gave credence to the testimonies of Florenda Dolera (Aurelio’s sister), Amelita Basalo (Aurelio’s niece), and Saul Curiba, who all testified to hearing Aurelio identify Dejillo and Hoyle as his attackers. However, the defense argued that these testimonies were belated claims, made only after a significant delay, and should not be given evidentiary weight. They also pointed out that Petronilo Dejillo, Sr., Dante’s father, was present when Aurelio was found and testified that Aurelio was unable to speak. Furthermore, the defense questioned the credibility of Romeo Puracan, the eyewitness, who was initially charged with the crime.

In evaluating the evidence, the RTC considered not only the dying declaration but also the eyewitness testimony of Romeo Puracan. Romeo testified that he saw Gervacio Hoyle holding Aurelio while Dante Dejillo stabbed him. The court found Romeo’s testimony to be credible and consistent with the NBI Exhumation Report and the testimony of Dr. Hamilcar Lauroy Saniel, the municipal health officer. The consistency between Romeo’s account and the medical evidence bolstered the prosecution’s case. Eyewitness testimony, when credible and consistent with other evidence, can be a powerful tool in establishing guilt beyond a reasonable doubt.

The defense presented an alibi, with Dante Dejillo claiming he was at home at the time of the stabbing. However, the court found this alibi to be weak and insufficient to overcome the positive identification of Dejillo by the prosecution witnesses. The court noted that Dejillo’s house was only 200 meters from the crime scene, making it possible for him to be present at the time of the stabbing. An alibi must be so convincing as to preclude any doubt that the accused could not have been physically present at the place of the crime, as highlighted in People v. Lacao, Sr., 201 SCRA 317. In this case, Dejillo’s alibi failed to meet this standard.

The Court of Appeals affirmed the RTC’s decision, emphasizing that the delay in reporting Aurelio’s dying declaration did not impair the credibility of the prosecution witnesses. The appellate court noted that Florenda Dolera had immediately requested the police to arrest Dejillo and Hoyle, but the police declined due to lack of evidence. It was only after seeking the NBI’s assistance that a formal complaint was lodged. The appellate court reasoned that the victim’s family would not have gone through such a tedious process to falsely convict the wrong persons. The absence of any ulterior motive on the part of the witnesses further strengthened their credibility.

The Supreme Court, in its decision, gave great weight to the factual findings of the RTC, recognizing the trial judge’s unique opportunity to observe the witnesses and assess their credibility. The Court reiterated that the matter of assigning values to declarations on the witness stand is best performed by the trial judge. This is because the trial judge can observe the demeanor of the witnesses, their forthrightness, and their overall credibility in a way that cannot be reflected in the written record.

Regarding the qualifying circumstance, the RTC found that the prosecution had established abuse of superior strength. This was evident in the fact that two accused-appellants used their combined strength and a bladed weapon to ensure the success of the crime. While the prosecution failed to prove treachery and evident premeditation, the presence of superior strength was sufficient to qualify the killing as murder. Abuse of superior strength exists when the offender takes advantage of his natural advantage, or uses means out of proportion to the victim’s means of defense.

As a result, the Supreme Court affirmed the conviction for murder, sentencing Dejillo and Hoyle to reclusion perpetua. However, the Court clarified that they would not be eligible for parole, in accordance with Section 3 of Republic Act No. 9346. The Court also affirmed the awards of civil indemnity (P50,000.00), moral damages (P50,000.00), and temperate damages (P25,000.00). Additionally, the Court awarded exemplary damages of P30,000.00, due to the presence of the qualifying circumstance of abuse of superior strength.

FAQs

What was the key issue in this case?	The key issue was whether the evidence presented, including the dying declaration and eyewitness testimony, was sufficient to prove beyond reasonable doubt that Dante Dejillo and Gervacio Hoyle, Jr. were guilty of murder. The Court had to determine the admissibility and weight of the dying declaration and the credibility of the eyewitness account.
What is a dying declaration?	A dying declaration is a statement made by a person who believes that his or her death is imminent, concerning the cause and circumstances of his or her impending death. It is admissible in court as an exception to the hearsay rule, provided certain conditions are met.
What are the requisites for a valid dying declaration?	The requisites include that the declaration must concern the crime and the circumstances of the declarant’s death, be made under a consciousness of impending death, come from a competent witness, and be offered in a case for homicide, murder, or parricide where the declarant is the victim. All four requisites must concur for the declaration to be admissible.
Why is a dying declaration considered reliable evidence?	Courts consider dying declarations reliable because it is believed that a person facing imminent death is unlikely to lie, as they would not want to meet their maker with a falsehood on their lips. This belief gives dying declarations a high degree of credibility.
What is the significance of eyewitness testimony in this case?	The eyewitness testimony of Romeo Puracan was significant because it corroborated the dying declaration of the victim. His detailed account of the stabbing incident, which aligned with the medical evidence, helped to establish the guilt of the accused beyond a reasonable doubt.
What is abuse of superior strength?	Abuse of superior strength is a qualifying circumstance in murder when the offender takes advantage of his natural advantage or uses means out of proportion to the victim’s means of defense. In this case, the combined strength of the two accused and their use of a weapon demonstrated superior strength.
What is the penalty for murder under the Revised Penal Code?	Under Article 248 of the Revised Penal Code, as amended, the penalty for murder is reclusion perpetua to death. The specific penalty imposed depends on the presence of mitigating or aggravating circumstances.
Are those convicted of reclusion perpetua eligible for parole?	No, under Section 3 of Republic Act No. 9346, persons convicted of offenses punished with reclusion perpetua are not eligible for parole under the Indeterminate Sentence Law. This ensures that those who commit heinous crimes serve their sentences without the possibility of early release.

The Supreme Court’s decision in People v. Dejillo serves as a reminder of the critical role that dying declarations and credible eyewitness testimony play in securing justice for victims of violent crimes. The case reinforces the principle that while each piece of evidence must be carefully scrutinized, a consistent narrative supported by multiple sources can overcome defenses and establish guilt beyond a reasonable doubt, contributing to a more just and equitable legal system.

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 vs. Dejillo, G.R. No. 185005, December 10, 2012