**Facts**: Carlos Jay Adlawan was charged with Frustrated Murder and Attempted Robbery against his stepmother, Georgia R. Adlawan, with incidents dating back to 18 February 2004. After his arraignment, a trial ensued detailing the sequence of events leading to Georgia’s multiple injuries inflicted by Adlawan using a katana. Adlawan’s defense hinged on the testimony of a houseboy, Cornelio Selin, who presented an alternative series of events leading to Georgia’s injuries, involving an accidental fall. The weapons supposedly used in the attack were seized without a warrant, complicating the evidence’s admissibility. Upon conclusion, the Regional Trial Court acquitted Adlawan of attempted robbery but found him guilty of frustrated homicide, a decision later affirmed with modifications by the Court of Appeals. The appeals court’s decision was challenged, not only on grounds of evidential mishandling and witness credibility but also regarding an Affidavit of Recantation and Desistance by the complainant, Georgia.
**Issues**:
1. Was there a grave failure of appellate review by the Court of Appeals, rendering its decision void?
2. Did the Court of Appeals err in disregarding the private complainant’s Affidavit of Recantation and Desistance as grounds for dismissing the action?
**Court’s Decision**:
The Supreme Court denied the petition, affirming the decisions of the Court of Appeals. It reiterated that the petition involved questions of fact not reviewable in a certiorari petition under Rule 45 of the Rules of Court. Importantly, it found no appellate review failure, holding that the CA thoroughly considered and rightfully affirmed the trial court’s factual findings. Additionally, it ruled that Georgia’s Affidavit of Recantation and Desistance did not carry enough weight to dismiss the case or overturn Adlawan’s conviction due to the credibility of her in-court testimonies and the lack of special circumstances that would cast doubt on her original statements.
**Doctrine**: In criminal cases, appellate courts largely defer to the trial court’s assessment of witness credibility, especially when corroborated by substantial evidence. Further, retraction affidavits, especially post-conviction, are typically viewed with suspicion and are insufficient to overturn a conviction on their own.
**Class Notes**:
– *Intent to Kill*: In cases of frustrated homicide, intent to kill can be inferred from the method of attack and the nature, location, and severity of the injuries inflicted.
– *Admissibility of Evidence*: The legality of how evidence is obtained (e.g., weapons seized without a warrant) can significantly affect its admissibility and impact on the case.
– *Witness Credibility*: The credibility of witness testimony is crucial and usually determined by the trial court, with appellate courts deferring to these findings unless there are substantial reasons not to.
– *Recantation*: An affidavit of recantation is not deemed sufficient to overturn a conviction, especially if it occurs after a conviction and lacks corroborating circumstances that introduce reasonable doubt regarding the accused’s guilt.
**Historical Background**: This case reflects on the intricate dynamics of stepfamily relationships and the complexities involved in criminal litigation, especially regarding evidence handling, witness credibility, and the impact of recantations in the Philippine judicial system.
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