*People of the Philippines vs. Francisco Juan Larrañaga, et al.*
### Facts:
On the evening of July 16, 1997, Marijoy and Jacqueline Chiong were abducted from Ayala Center in Cebu City by Rowen Adlawan, Josman Aznar, Ariel Balansag, Francisco Juan Larrañaga, and other co-accused. They were forced into a vehicle, taken to a house where they were molested, then moved to a more remote location.
The arrested suspects were charged and detailed evidence was presented in the trial:
1. At nightfall, Rowen and Josman approached the Chiong sisters, forcibly dragging them into a car.
2. They were then transferred to a ‘safe house,’ where further abuses transpired.
3. The group later brought the girls to Tan-awan, Carcar, where Marijoy was thrown off a cliff to her death while Jacqueline disappeared, never to be found.
**Key Points in the Procedural History:**
1. The police were initially unable to locate the sisters until Marijoy’s body was discovered on July 18, 1997.
2. State witness Davidson Rusia implicated himself and the appellants in the crimes and led police to the key facts.
3. Multiple witnesses testified, corroborating Rusia’s account. However, the defense claimed alibis for each of the accused.
4. The trial court in Cebu found the defendants guilty in Criminal Cases Nos. CBU-45303-45304, sentencing them to reclusion perpetua.
5. The appellants challenged this decision, raising several assignments of error before the Supreme Court.
### Issues:
1. **Due Process**: Did the trial court violate the appellants’ right to due process, including their right to counsel and the opportunity to cross-examine?
2. **State Witness**: Was Davidson Rusia’s discharge as a state witness proper, considering the rules on qualifications?
3. **Credibility of Prosecution**: Did the prosecution present sufficient credible evidence to warrant the conviction of the appellants?
4. **Defense of Alibi**: Was the appellants’ defense of alibi sufficient to create reasonable doubt about their guilt?
### Court’s Decision:
1. **Due Process**:
– The court recognized the issues surrounding the length and readiness of the defense counsel, ruling that appointing a counsel de oficio was necessary due to dilatory tactics and maintaining trial continuity.
– The trial court was found to have provided ample opportunity for cross-examination and a fair trial process, rejecting claims of bias or undue interference by the presiding judge.
2. **State Witness**:
– The court upheld the discharge of Rusia as a state witness. Though challenged, the court ruled that Rusia was not the “most guilty,” and his previous conviction did not bar his testimony’s credibility.
– The discharge, despite the defense’s substantial cross-examination effort, stood as it adhered to procedural rules.
3. **Credibility of Prosecution**:
– The court found that prosecution witnesses corroborated crucial elements, discrediting the alibi defense’s evidence.
– Testimonies and physical evidence, including the identification of Marijoy’s body, aligned with Rusia’s narrative, deemed reliable.
4. **Defense of Alibi**:
– The defense failed to show physical impossibility of the accused being present at the crime scene, given the travel timeframe between Manila and Cebu.
– Witnesses for the defense were inconsistent and less credible compared to prosecution testimonies and evidence.
### Doctrine:
**Due process and fair trial instructions**: Courts can appoint counsels de officio during strategic withdrawals to preserve trial efficacy. There is a substantial judicial role in managing lengthy and potentially prejudicial defense tactics.
### Class Notes:
– **Due Process Violations**: Procedural fairness requires effective representation and reasonable opportunity for defense. Courts can appoint substitute counsel if needed.
– **Discharge of State Witnesses**: Must fulfill conditions like not being the most guilty. Prior convictions of moral turpitude do not automatically disqualify their credible testimony.
– **Appellate Review**: Supreme Court reaffirmed lower court’s findings based on sufficiency and credibility of evidence.
### Historical Background:
The Chiong sisters’ case became highly publicized, known as Cebu’s “trial of the century,” highlighting the judiciary’s challenges in managing high-profile criminal cases with intense public and media scrutiny.
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