People v. Coca Jr., G.R. No.

133739, May 29, 2002, 382 SCRA 508

MURDER
Accused-appellants and the victim, Edilberto Banate, were related by affinity, and all
residents of Cabulihan, Guba, Cebu City. Brothers Ricardo Coca and Tomas Coca, Jr.
are the first degree cousins of Merolina Banate, the victim’s wife; while Ramil Coca is
the son of Ricardo Coca.
On March 13, 1996 at 9pm Tomas Ricardo and Ramil Coca mauled (sinaktan) Edilberto
Banate. Banate sustained injuries including his broke left shoulder? A week later on
March 20, 1996 at 7pm the victim was eating with his wife and two children inside their
kitchen. A sudden burst of gunfire emanated from underneath the house. Sumilip si
Merolina through the slits on the floor at saw the 3 man sitting on their heels. Because
of the florescent lamp illuminated their kitchen and the 100 watt bulb of the adjacent
house Merolina enable to identity the accused, which is Tomas, Ricardo and Ramil
Coca who were all underneath the house and looking upward. Tomas was between
Ricardo and Ramil and aiming a gun at Banate. When Merolina turned she saw her
husband, slumped on the floor covered in blood.
Meanwhile, Alexander Singsong, a visitor of Banate family who left earlier to buy
cigarettes was alerted by the gunshots. Dali dali sya pumunta sa scene and saw the 3
running away from the house of Banate. Then he helped bringing Edilberto to the
hospital.
The victim sustained a massive gunshot would on the chest. The bullet pierced the right
rib, penetrating the pulmonary region all the way to, and fracturing the spinal column,
where the slug was embedded. As a consequence, the victim became paralyzed from
waist down. He eventually died on July 2, 1996.
Sinadya ni Merolina na itago ang identity ng 3 culprit because she was afraid to
endanger not only her life but also that of her children who were alone in their house all
through out the time that she was in the hospital with her injured husband. On August
19, 1996, almost 5 months whe she finally reveal the identity of the perpetrators.
On the other hand, accused raised of denial and alibi. Tomas Coca testified that on
March 20, 1996 at about 7pm he and Ricardo Coca attended a birthday party in the
house of Mario Rebales at Cabulihan , Guba, Cebu City. The Ramil Coca arrived and
informed them that Banate was shot. The Tomas followed Ricardo and Pedro Soquib to
the house of the victim but did not proceed when he noticed na wala ng tao dun. This
was corroborated by Ricardo ( he was hired to cook food for the birthday party of
Rabales daughter )
Ramil affirmed the version of Ricardo and Tomas. He added that on the night of March
20, 1996 he was eating with his family when he heard 3 gunshots. When he and his
mother went out and check what happened, they saw Roel Soquib and Melino Leyson
carrying the body of the victim. At the instructions of his mother, he proceeded to the
house of Mario Rabales to inform his father about the incident. Then his father, Ramil
and Perdo Soquib followed by Tomas went to the crimescene.
The version of the defense was further corroborated by the testimonies of defense
witnesses Pedro Soquib and Mario Rebales.14 Defense witnesses Sergio Borres and
Roel Soquib, who helped bring the victim to the hospital, further narrated that Merolina
Banate told them that she was not able to recognize the culprit because it was dark.
On July 30, 1997, the trial court rendered the assailed judgment of conviction ;
In their appeal, accused contend that the prosecution failed to establish beyond
reasonable doubt the identity of the perpetrators. They claimed that at 7:00 in the
evening, it was impossible for Merolina Banate to recognize the culprits through a ¾
inch gap on the bamboo flooring, considering that the area underneath the house where
the gunfire allegedly came from was dark. In the same vein, accused assert that the
testimony of Alexander Singson is fabricated. According to them, it is unbelievable that
Singson had committed to memory the appearance of the assailants not only because it
was dark, but also because Singson himself admitted that he saw the assailants only for
the first time during the incident. They further argued that if Merolina indeed recognized
the perpetrators, she would have immediately revealed their names to those who
responded and to the members of the media who interviewed her.
Accused likewise alleged that Merolina’s reaction immediately after the incident was
contrary to human experience. The natural reaction would have been to seek cover, turn
off the light, shout for help, or cuddle the injured, and not to peep through the floor
where the shots came from. Finally, accused-appellants Ricardo and Ramil Coca
contend that even assuming that the version of the prosecution were true, they should
have been acquitted considering that there was no evidence to show that they connived
with accused-appellant Tomas Coca, Jr.
Visibility is indeed a vital factor in the determination of whether or not an eyewitness
have identified the perpetrator of a crime. However, it is settled that when conditions of
visibility are favorable, and the witnesses do not appear to be biased, their assertion as
to the identity of the malefactor should normally be accepted. Illumination produced by
kerosene lamp or a flashlight is sufficient to allow identification of persons. Wicklamps,
flashlights, even moonlight or starlight may, in proper situations, be considered sufficient
illumination, making the attack on the credibility of witnesses solely on that ground
unmeritorious.17
In the case at bar, the kitchen/dining area where the victim was shot from underneath
the house was illuminated by a fluorescent lamp. There would therefore be light falling
on the faces of accused, especially so that they were all facing upwards. Ordinary
human experience would tell us that bamboo flooring with gaps smaller than an inch
allows every ray of light emanating from a fluorescent lamp to freely penetrate through
the bamboo slats. With this environmental milieu, the fluorescent lamp would indeed
provide sufficient illumination to identify the accused underneath a 3 to 4 feet high
bamboo flooring. What is more, the 100 watt bulb of the adjacent house, six meters
away, and directly opposite the kitchen where the victim was shot, provided additional
illumination below the victim’s house. Clearly, therefore, the circumstances surrounding
the commission of the crime certainly obliterate the slightest shred of doubt on the
veracity of accused-appellant’s identification.
Moreover, it is not amiss to state that “relatives of a victim of a crime have a natural
knack for remembering the face of the assailant and they, more than anybody else,
would be concerned with obtaining justice for the victim by the malefactor being brought
to the face of the law.” Indeed, family members who have witnessed the killing of a
loved one usually strive to remember the faces of the assailants. With more reason
therefore that we should believe the positive identification of accused-appellants by
Merolina Banate. Being close blood relatives and residents of the same barangay,
Merolina would naturally and particularly be familiar with the face and build of accused-
appellants.
During the question and answered Merolina stayed and consistent in her identification
because they are her close relative.
There is treachery when the offender commits any of the crimes against persons,
employing means, methods, or forms in the execution thereof which tend to directly and
specially insure the execution of the crime, without risk to himself arising from the
defense which the offended party might make. The essence of treachery is the sudden,
unexpected, and unforeseen attack on the person of the victim, without the slightest
provocation on the part of the latter. Judging from the circumstances which attended the
shooting of the deceased, treachery undoubtedly qualified the present case to murder.
This is so because accused-appellants obviously devised a way, that is, by shooting the
victim from underneath the house, to effectively execute the crime without risk to
themselves arising from the defense which the unsuspecting victim might put

In sum, the Court finds that the trial court did not err in upholding the version of the
prosecution and disregarding the defenses put up by accused-appellants. Though
Merolina did not see the actual shooting of her husband, the circumstantial evidence
presented by the prosecution is sufficient to sustain a conviction. Under the Rules of
Court, conviction based on circumstantial evidence is sufficient if: (a) there is more than
one circumstance; (b) the facts from which the inferences are derived are proven; and
(c) the combination of all the circumstances is such as to produce a conviction beyond
reasonable doubt. Here, more than one circumstance was presented by the
prosecution. The victim’s wife heard gunshots from underneath their house. Immediately
thereafter, she peeped through their bamboo flooring and saw the three accused-
appellants sitting on their heels and looking upwards. Accused-appellant Tomas Coca,
Jr. was holding a gun pointed upwards while seated between accused-appellants
Ricardo and Ramil Coca. When she turned to her husband, she saw that he was shot.
As the three accused-appellants fled, prosecution witness Alexander Singson saw them
running away from the house of the victim. All these, added to accused-appellants’
previous altercation with the victim, form an unbroken chain of circumstances pointing to
accused-appellants, and no other, as the persons responsible for the victim's death.
The trial court did not overlook any fact of weight and substance which, if properly
considered, would have altered the result of the case. Hence, its findings of facts and
assessment of the credibility of the witnesses deserve to be sustained on appeal. For
having had the distinct opportunity of directly observing the demeanor and conduct of
the witnesses under oath, the trial court is in a better position to ascertain whether or
not a witness is telling the truth.
The penalty for the crime of murder is reclusion perpetua to death
 Sanson v. Court of Appeals, G.R. No. 127745, April 22, 2003, 401 SCRA 349
On February 7, 1990, herein petitioner Felicito G. Sanson (Sanson), in his capacity as
creditor, filed before the Regional Trial Court (RTC) of Iloilo City a petition, docketed as
Special Proceedings No. 4497, for the settlement of the estate of Juan Bon Fing Sy (the
deceased) who died on January 10, 1990. Sanson claimed that the Sy was indebted to
him in the amount of P603,000.00 and to his sister Celedonia Sanson-Saquin
(Celedonia) in the amount of P360,000.00.
Petitioners Eduardo Montinola, Jr. and his mother Angeles Montinola (Angeles) later
filed separate claims against the estate, alleging that the deceased owed them
P50,000.00 and P150,000.00, respectively.
In February 12, 1991, Branch 28 of the Iloilo RTC appointed Melecia T. Sy as the
administratrix of her deceased spouse’s estate, and she was given letters of
administration.
During the hearing of the claims against the estate, Sanson, Celedonia, and Jade
Montinola, wife of claimant Eduardo Montinola, Jr., testified on the transactions that
gave rise thereto, over the objection of the administratrix who invoked Section 23, Rule
130 of the Revised Rules of Court otherwise known as the Dead Man’s Statute which
reads:
SEC. 23. Disqualification by reason of death or insanity of adverse party.—Parties or
assignors of parties to a case, or persons in whose behalf a case is prosecuted, against
an executor or administrator or other representative of a deceased person, or against a
person of unsound mind, upon a claim or demand against the estate of such deceased
person or against such person of unsound mind, cannot testify as to any matter of fact
occurring before the death of such deceased person or before such person became of
unsound mind. (Emphasis supplied)
This legal provision states that if someone is involved in a legal case against a person
who has died or is mentally unfit, they cannot give testimony about any facts that
occurred before the person died or became mentally unfit.
In simpler terms, if you’re suing someone’s estate after they’ve passed away, or if
you’re suing someone who is mentally incapacitated, you can’t provide testimony about
events that happened before they died or became mentally incapacitated. This rule is in
place to prevent potential bias or unfairness in the legal process
Sanson, in support of the claim of his sister Celedonia, testified that she had a
transaction with the deceased which is evidenced by six checks issued by him before
his death; before the deceased died, Celedonia tried to enforce settlement of the checks
from his (the deceased’s) son Jerry who told her that his father would settle them once
he got well but he never did; and after the death of the deceased, Celedonia presented
the checks to the bank for payment but were dishonored due to the closure of his
account.
Celedonia, in support of the claim of her brother Sanson, testified that she knew that the
deceased issued five checks to Sanson in settlement of a debt; and after the death of
the deceased, Sanson presented the checks to the bank for payment but were returned
due to the closure of his account.
Jade, in support of the claims of her husband Eduardo Montinola, Jr. and mother-in-law
Angeles, testified that on separate occasions, the deceased borrowed P50,000 and
P150,000 from her husband and mother-in-law, respectively, as shown by three checks
issued by the deceased, two to Angeles and the other to Eduardo Montinola, Jr.; before
the deceased died or sometime in August 1989, they advised him that they would be
depositing the checks, but he told them not to as he would pay them cash, but he never
did; and after the deceased died on January 10, 1990, they deposited the checks but
were dishonored as the account against which they were drawn was closed, hence,
their legal counsel sent a demand letter dated February 6, 1990 addressed to the
deceased’s heirs Melicia, James, Mini and Jerry Sy, and Symmels I & II but the checks
have remained unsettled.
The administratrix, denying having”any knowledge or information sufficient to form a
belief as to the truth of the claims, nevertheless alleged that if they ever existed, they
had been paid and extinguished, are usurious and illegal and are, in any event, barred
by prescription. And she objected to the admission of the checks and check return slips-
exhibits offered in evidence by the claimants upon the ground that the witnesses who
testified thereon are disqualified under the Dead Man’s Statute.
Specifically with respect to the checks-exhibits identified by Jade, the administratrix
asserted that they are inadmissible because Jade is the daughter-in-law of claimant
Angeles and wife of claimant Eduardo Montinola, Jr., hence, she is covered by the
above-said rule on disqualification.
At all events, the administratrix denied that the checks-exhibits were issued by the
deceased and that the return slips were issued by the depository/clearing bank.
After the claimants rested their case, the administratrix filed four separate
manifestations informing the trial court that she was dispensing with the presentation of
evidence against their claims.
Finding that the Dead Man’s Statute does not apply to the witnesses who testified in
support of the subject claims against the estate, the trial court issued an Order of
December 8, 1993 the dispositive portion of which reads:
WHEREFORE, Judicial Administratrix Melecia T. Sy, is hereby ordered, to pay, in due
course of administration, creditors-claimants Felicito G. Sanson, in the amount of
P603,500.00; Celedonia S. Saquin, in the amount of P315,000.00; Angeles A.
Montinola, in the amount of P150,000.00 and Eduardo Montinola, Jr., in the amount of
P50,000.00, from the assets and/or properties of the above-entitled intestate estate.
On appeal by the administratrix upon the following assignment of errors:
I.
THE LOWER COURT ERRED IN NOT DISMISSING THE CLAIM[S] FOR FAILURE TO
PAY THE FILING FEES THEREON
II.
THE LOWER COURT ERRED IN NOT DISMISSING THE CLAIM[S] BECAUSE [THEY
ARE] ALREADY BARRED BY THE LAW OF LIMITATIONS OR STATUTE OF NON-
CLAIMS
III.
THE LOWER COURT ERRED IN NOT HOLDING THAT CLAIMANT[S’] EVIDENCE OF
THE CLAIM IS INCOMPETENT UNDER THE DEAD MAN’S STATUTE, AND
INADMISSIBLE
IV.
THE ALLEGED CHECKS ARE INADMISSIBLE AS PRIVATE DOCUMENTS,
The Court of Appeals set aside the December 8, 1993 Order of the trial court, by
Decision of May 31, 1996, disposing as follows:

WHEREFORE, the order appealed from is hereby set aside and another order is
entered dismissing the claims of:
1. Felicito G. Sanson, in the amount of P603,500.00;
2. Celdonia S. Saquin, in the amount of P315,000.00;20
3. Angeles A. Montinola, in the amount of P150,000.00; and
4. Eduardo Montinola, Jr., in the amount of P50,000.00 against the estate of the
deceased JUAN BON FING SY.
No pronouncement as to costs.
SO ORDERED. (Italics supplied)
The claimants’ Motion for Reconsideration21 of the Court of Appeals decision having
been denied by Resolution of December 9, 1996,22 they filed the present petition
anchored on the following assigned errors:
FIRST ASSIGNED ERROR
RESPONDENT COURT OF APPEALS, 4TH DIVISION, ERRED IN FINDING THAT THE
TESTIMONY OF JADE MONTINOLA IS INSUFFICIENT TO PROVE THE CLAIMS OF
CLAIMANTS ANGELES A. MONTINOLA AND EDUARDO A. MONTINOLA, JR..
SECOND ASSIGNED ERROR
RESPONDENT COURT OF APPEALS, 4TH DIVISION, ERRED IN FINDING THAT
CLAIMANT FELICITO G. SANSON IS DISQUALIFIED TO TESTIFY [ON] THE CLAIM
OF CELEDONIA SANSON-SA[Q]UIN AND VI[C]E VERSA. (Underscoring in the
original)
With respect to the first assigned error, petitioners argue that since the administratrix did
not deny the testimony of Jade nor present any evidence to controvert it, and neither did
she deny the execution and genuineness of the checks issued by the deceased (as well
as the check return slips issued by the clearing bank), it was error for the Court of
Appeals to find the evidence of the Montinolas insufficient to prove their claims.
The administratrix counters that the due execution and authenticity of the checks-
exhibits of the Montinolas were not duly proven since Jade did not categorically state
that she saw the filling up and signing of the checks by the deceased, hence, her
testimony is self-serving; besides, as Jade had identical and unitary interest with her
husband and mother-in-law, her testimony was a circumvention of the Dead Man’s
Statute.
The administratrix’s counter-argument does not lie. Relationship to a party has never
been recognized as an adverse factor in determining either the credibility of the witness
or—subject only to well recognized exceptions none of which is here present—the
admissibility of the testimony. At most, closeness of relationship to a party, or bias, may
indicate the need for a little more caution in the assessment of a witness’ testimony but
is not necessarily a negative element which should be taken as diminishing the credit
otherwise accorded to it.
Jade’s testimony on the genuineness of the deceased’s signature on the checks-
exhibits of the Montinolas is clear:
Q: Showing to you this check dated July 16, 1989, Far East Bank and Trust
Company Check No. 84262, in the amount of P100,000.00, is this the check you are
referring to?
A: Yes, sir.

Q: There appears a signature in the face of the check. Whose signature is this?
A: That is the signature of Mr. Sy.
Q: Why do you know that this is the signature of Mr. Sy?
A: Because he signed this check I was . . . I was present when he signed this
check.
Q: Showing to you this check dated September 8, 1989, is this the check you are
referring to?
A: Yes, sir.
Q: Why do you know that this is his signature?
A: I was there when he signed the same.
Q: Showing to you this Far East Bank and Trust Company Check No. 84262 dated
July 6, 1989, in the amount of P50,000.00, in the name of Eduardo Montinola, are you
referring to this check?
A: Yes, sir.
Q: Whose signature is this appearing on the face of this check?
A: Mr. Sy’s signature.
Q: Why do you know that it is his signature?
A: I was there when he signed the same.
The genuineness of the deceased’s signature having been shown, he is prima facie
presumed to have become a party to the check for value, following Section 24 of the
Negotiable Instruments Law which reads:
Section 24. Presumption of Consideration. – Every negotiable instrument is deemed
prima facie to have been issued for a valuable consideration; and every person whose
signature appears thereon to have become a party thereto for value. (Underscoring and
italics in the original; emphasis supplied),
Since, with respect to the checks issued to the Montinolas, the prima facie presumption
was not rebutted or contradicted by the administratrix who expressly manifested that
she was dispensing with the presentation of evidence against their claims, it has
become conclusive.
As for the administratrix’s invocation of the Dead Man’s Statute, the same does not
likewise lie. The rule renders incompetent: 1) parties to a case; 2) their assignors; or 3)
persons in whose behalf a case is prosecuted.
The rule is exclusive and cannot be construed to extend its scope by implication so as
to disqualify persons not mentioned therein. Mere witnesses who are not included in the
above enumeration are not prohibited from testifying as to a conversation or transaction
between the deceased and a third person, if he took no active part therein.
Jade is not a party to the case. Neither is she an assignor nor a person in whose behalf
the case is being prosecuted. She testified as a witness to the transaction. In
transactions similar to those involved in the case at bar, the witnesses are commonly
family members or relatives of the parties. Should their testimonies be excluded due to
their apparent interest as a result of their relationship to the parties, there would be a
dearth of evidence to prove the transactions. In any event, as will be discussed later,
independently of the testimony of Jade, the claims of the Montinolas would still prosper
on the basis of their documentary evidence—the checks.
As to the second assigned error, petitioners argue that the testimonies of Sanson and
Celedonia as witnesses to each other’s claim against the deceased are not covered by
the Dead Man’s Statute; besides, the administratrix waived the application of the law
when she cross-examined them.
The administratrix, on the other hand, cites the ruling of the Court of Appeals in its
decision on review, the pertinent portion of which reads:
The more logical interpretation is to prohibit parties to a case, with like interest, from
testifying in each other’s favor as to acts occurring prior to the death of the deceased.
Since the law disqualifies parties to a case or assignors to a case without distinguishing
between testimony in his own behalf and that in behalf of others, he should be
disqualified from testifying for his co-parties. The law speaks of “parties or assignors of
parties to a case.” Apparently, the testimonies of Sanson and Saquin on each other’s
behalf, as co-parties to the same case, falls under the prohibition. (Citation omitted;
underscoring in the original and emphasis supplied)
But Sanson’s and Celedonia’s claims against the same estate arose from separate
transactions. Sanson is a third party with respect to Celedonia’s claim. And Celedonia is
a third party with respect to Sanson’s claim. One is not thus disqualified to testify on the
other’s transaction.
In any event, what the Dead Man’s Statute proscribes is the admission of testimonial
evidence upon a claim which arose before the death of the deceased. The
incompetency is confined to the giving of testimony.29 Since the separate claims of
Sanson and Celedonia are supported by checks-documentary evidence, their claims
can be prosecuted on the bases of said checks.
This brings this Court to the matter of the authenticity of the signature of the deceased
appearing on the checks issued to Sanson and Celedonia. By Celedonia’s account, she
“knows” the signature of the deceased.
Q: Showing to you these checks already marked as Exhibit “A” to “E”, please go
over these checks if you know the signatures of the late Juan Bon Fing Sy? On these
checks?
A: Yes, sir.
Q: Insofar as the amount that he borrowed from you, he also issued checks?
A: Yes, sir.
Q: And therefore, you know his signature?
A: Yes, sir.
Sanson testified too that he “knows” the signature of the deceased:
Q: I show you now checks which were already marked as Exhibit “A” to “G-1” –
Saquin, please go over this if these are the checks that you said was issued by the late
Juan Bon Fing Sy in favor of your sister?
A: Yes, these are the same che[c]ks.
Q: Do you know the signature of the late Juan Bon Fing Sy?
A: Yes, sir.
Q: And these signatures are the same signatures that you know?
A: Yes, sir.
While the foregoing testimonies of the Sanson siblings have not faithfully discharged the
quantum of proof under Section 22, Rule 132 of the Revised Rules on Evidence which
reads:
Section 22. How genuineness of handwriting proved. – The handwriting of a person
may be proved by any witness who believes it to be the handwriting of such person
because he has seen the person write, or has seen writing purporting to be his upon
which the witness has acted or been charged and has thus acquired knowledge of the
handwriting of such person.
Not only did the administratrix fail to controvert the same; from a comparison32 with the
naked eye of the deceased’s signature appearing on each of the checks-exhibits of the
Montinolas with that of the checks-exhibits of the Sanson siblings all of which checks
were drawn from the same account, they appear to have been affixed by one and the
same hand.
In fine, as the claimants-herein petitioners have, by their evidence, substantiated their
claims against the estate of the deceased, the burden of evidence had shifted to the
administratrix who, however, expressly opted not to discharge the same when she
manifested that she was dispensing with the presentation of evidence against the
claims.
WHEREFORE, the impugned May 31, 1996 Decision of the Court of Appeals is hereby
SET ASIDE and another rendered ordering the intestate estate of the late Juan Bon
Fing Sy, through Administratrix Melecia T. Sy, to pay:
1) Felicito G. Sanson, the amount of P603,500.00;
2) Celedonia S. Saquin, the amount of P315.000.00;33
3) Angeles Montinola, the amount of P150,000.00; and
4) Eduardo Montinola, Jr., the amount of P50,000.00.
Representing unsettled checks issued by the deceased.
 Zulueta v. Court of Appeals, G.R. No. 107383, February 20, 1996, 253 SCRA697

4. People v. Sandiganbayan, G.R. Nos. 115439-41, July 16, 1997, 275 SCRA 505
5. Gonzales v CA, G.R. No. 117740, October 30, 1998, 298 SCRA 322
6. People v. Invention, G.R. No. 131636, March 5,2003, 398 SCRA 592
7. People v. Judge Ayson, G.R. No. 85215, July 7, 1989, 175 SCRA 216
8. Dans Jr. v. People, G.R. No. 127073, January 29, 1998, 285 SCRA 505
9. Estrada v. Desierto, G.R. Nos. 146710-15, April 3, 2001 Resolution, 356 SCRA 108
10. People v. Gaudia, G.R. No. 146111, February 23, 2004, 423 SCRA 520
11. People v. Raquel, G.R. No. 119005, December 2,1996, 265 SCRA 248
12. People v. Using, G.R. No. 106210-11, January 30,1998, 285 SCRA 595
13. People v. Sabagala, G.R. No. 131040, October 5, 2001, 366 SCRA 618
14. People v. Cui, G.R. No. 121982, September 10, 1999, 314 SCRA 153
15. People v. Flores, G.R. No. 71980, March 18, 1991, 195 SCRA 295
16. People v. Abo, G.R. No. 107235, March 2,1994, 230 SCRA 612
17. People v. Alegre, G.R. No. L-30423, November 7, 1979, 94 SCRA 109
18. People v. Paragsa, G.R. No. L-44060, July 20, 1978, 84 SCRA 105
19. People v. Lorenzo, G.R. No. 110107, January 26, 1995, 240 SCRA 624
20. People v. Rapeza, G.R. No. 169431, April 4, 2007, 520 SCRA 596
21. Ladiana v. People, G.R. No. 144293, December 4, 2002, 393 SCRA 419
22. People v. Santos, G.R. No. 100225-26, May 11, 1993, 221 SCRA 715
23. People v. Dadles, G.R. Nos. 118620-21, September 1,1997, 278 SCRA 393
24. Patula v. People, G.R. No. 164457, April 11, 2012
25. People v. Gado, G.R. No. 129556, November 11, 1998, 298 SCRA 466
26. People v. Odencio, G.R. No. L-31961, January 9, 1979, 88 SCRA 1
27. People v. Santos, G.R. No. 94545, April 4, 1997, 270 SCRA 650
28. People v. Serenas, G.R. No. 188124, June 29, 2010, 622 SCRA 485
29. People v. Bernal, G.R. No. 113685, June 19, 1997, 274 SCRA 197
30. Parel v. Prudencio, G.R. No. 146556, April 19, 2006, 487 SCRA 405
31. People v. Pruna, G.R. No. 138471, October 10, 2002, 390 SCRA 577
32. People v. Palmones, G.R. No. 136303, July 18, 2000, 336 SCRA 80
33. People v. Villarama, G.R. No. 139211, February 12, 2003, 397 SCRA 306
34. People v. San Gabriel, G.R. No. 107735, February 1, 1996, 253 SCRA 84
35. Jimenez v. Commission on Ecumenical Mission and Relations of the Unit
Presbyterian Church in the USA, G.R. No. 140472, June 10, 2002, 383 SCRA 326
36. People v. Martinez, G.R. No. 116918, June 19, 1997, 274 SCRA 259
37. People v. Lee, G.R. No. 139070, May 29, 2002, 382 SCRA 598
38. People v. Edualino, G.R. No. 119072, April 11,1997, 271 SCRA 189
39. People v. Deopita, G.R. No. 130601, December 4, 2000, 436 SCRA 794