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Jimenez Vs People G.R. No. 209195 Sept 17,2014

Manuel Montero confessed to killing Ruby Rose Barrameda and named Manuel Jimenez and others as co-conspirators. Judge Docena granted Montero's motion to be discharged as a state witness, finding the prosecution presented clear evidence of compliance. Jimenez opposed, arguing the requirements were not met and Montero was not necessarily and was likely most guilty. The Supreme Court ruled that Judge Docena did not gravely abuse discretion, as Montero's testimony only needed to be substantially, not fully, corroborated on material points. The trial court has discretion to determine if the prosecution's assessment of a witness satisfies procedural standards.

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211 views1 page

Jimenez Vs People G.R. No. 209195 Sept 17,2014

Manuel Montero confessed to killing Ruby Rose Barrameda and named Manuel Jimenez and others as co-conspirators. Judge Docena granted Montero's motion to be discharged as a state witness, finding the prosecution presented clear evidence of compliance. Jimenez opposed, arguing the requirements were not met and Montero was not necessarily and was likely most guilty. The Supreme Court ruled that Judge Docena did not gravely abuse discretion, as Montero's testimony only needed to be substantially, not fully, corroborated on material points. The trial court has discretion to determine if the prosecution's assessment of a witness satisfies procedural standards.

Uploaded by

Amanda Love
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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MANUEL J. JIMENEZ, JR. vs.

PEOPLE OF THE PHILIPPINES


G.R. No. 209195, September 17, 2014

Facts:

Manuel A. Montero confessed his participation in the killing of Ruby Rose Barrameda naming
Manuel J. Jimenez and several others as co-conspirators. Montero detailed that the alleged steel
casing containing the body of Ruby Rose was dumped that led to the recovery of a cadaver, encased
in a drum and steel casing, near or practically at the place that Montero pointed to. Judge Zaldy B.
Docena granted the motion to discharge stating that the prosecution had presented clear,
satisfactory, and convincing evidence showing compliance with the requisites of granting the said
motion. Jimenez opposed Judge Docena’s ruling averring that the Judge committed grave abuse of
discretion in granting the motion to discharge because: (1) the requirements for granting a motion
were not properly complied; (2) there is no absolute necessity of the testimony of Montero; (3)
Montero’s testimony do not corroborate with the prosecution’s evidence; (4) and Montero is
favored as a state witness though he appears to be the most guilty.

Issue:

Whether or not Judge Docena commit grave abuse of discretion when he granted the motion to
discharge Montero as a state witness.

Ruling:

No. Under Section 17, Rule 119 of the Revised Rules of Criminal Procedure, it only requires that that
the testimony of the accused sought to be discharged be substantially corroborated in its material
points, not on all points. A trial judge cannot be expected or required, at the start of the trial, to
inform himself with absolute certainty of everything that may develop in the course of the trial with
respect to the guilty participation of the accused. The trial court still determines whether the
prosecution’s preliminary assessment of the accused-witness’ qualifications to be a state witness
satisfies the procedural norms. This relationship is in reality a symbiotic one as the trial court, by
the very nature of its role in the administration of justice, largely exercises its prerogative based on
the prosecutor’s findings and evaluation.

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