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Topic: Evidence; Falsus in uno, falsus in omnibus (False in one, False in all) Title: Northwest Airline v. Chiong G.R.

no. 155550, January 31, 2008 Ponente: Nachura, J. Facts: In the course of a civil proceeding, Northwest, filed a separate criminal complaint for False Testimony against Chiong based on the latters testimony that he did not leave the Philippines after April 1, 1989 contrary to the notations in his seaman service record book that he had left the country on April 17, 1989, and returned on October 5 of the same year. The RTC favored Chiong by the evidence that Chiong passed through the PCG counter on April 1, 1989, and that his passport was accordingly stamped, obviously for purposes of his departure on that day.
Issue: Is the falsus in uno, falsus in omnibus applicable? Ruling: No. Analysis: The legal maxim falsus in uno, falsus in omnibus, cited by Northwest, is not a positive rule of law and is not strictly applied in this jurisdiction. Before this maxim can be applied, the witness must be shown to have willfully falsified the truth on one or more material points. The principle presupposes the existence of a positive testimony on a material point contrary to subsequent declarations in the testimony. However, the records show that Chiongs testimony did not contain inconsistencies on what occurred on April 1, 1989. Yet, Northwest never even attempted to explain or impugn the evidence that Chiong passed through the PCG counter on April 1, 1989, and that his passport was accordingly stamped, obviously for purposes of his departure on that day.

Topic: Competent Evidence Title: People v. Judge Laguio, G.R. No. 128587 Ponente: Garcia, J March 16, 2007

Facts: Private respondent was walking from the Maria Orosa Apartment and was about to enter the parked BMW car when the police operatives arrested him. When frisked, there was found inside the front right pocket of Wang and confiscated from him an unlicensed guns and shabu in the car. Issue: Is the evidence competent? Ruling: no Analysis: There can be no valid warrantless arrest in flagrante delicto under paragraph (a) of Section 5 Rule 113 of the Rules on Criminal Procedure. It is settled that "reliable information" alone, absent any overt act indicative of a felonious enterprise in the presence and within the view of the arresting officers, is not sufficient to constitute probable cause that would justify an in flagrante delicto arrest. Hence the warrantless arrest was illegal. Ipso jure, the warrantless search incidental to the illegal arrest was likewise unlawful. Therefore the evidence obtained was illegal.