**Facts:** The case revolves around Carlos Jay Adlawan (“petitioner”), charged with Frustrated Murder and Attempted Robbery on March 5, 2004. The prosecution evidence revealed that Adlawan, unemployed and physically impaired due to leg surgeries, attacked his stepmother, Georgia R. Adlawan (“Georgia”), with a katana on February 18, 2004, causing several severe injuries. Georgia managed to escape and receive medical attention, leading to Adlawan’s indictment. The defense, through Cornelio Selin (“Cornelio”), presented an alternative narrative suggesting Georgia’s injuries resulted from accidental falls. The Regional Trial Court (RTC) acquitted Adlawan of attempted robbery but convicted him for frustrated homicide, considering the testimonies and medical evidence. Adlawan’s appeal to the Court of Appeals (CA) retained his conviction, slightly modulating the sentence. Adlawan filed for a motion for reconsideration and a joint motion to dismiss based on an affidavit of recantation and desistance by Georgia, which the CA denied. This led to the petitioner seeking a review from the Supreme Court, focusing on alleged appellate review failures and the CA’s disregard for the affidavit of recantation and desistance.
**Issues:** The Supreme Court was presented with two primary issues: 1) whether the CA failed in its appellate review by inadequately addressing the issues raised by Adlawan, and 2) whether the CA erred in disregarding Georgia’s affidavit of recantation and desistance.
**Court’s Decision:** The Supreme Court held that the petition lacked merit, affirming the CA’s decision. It clarified that the issues raised involved questions of fact, generally not reviewable under Rule 45 of the Rules of Court. It emphasized the deference given to the trial court’s factual findings, especially on matters of witness credibility and evidentiary relevance. The Court rejected the petitioner’s arguments on procedural and substantive grounds. It found no failure in the appellate review, recognizing the CA’s adherence to requisite standard practices, including the assessment of witness testimony and evidence. Moreover, the Court ruled against the argument on Georgia’s affidavit of desistance, explaining the general skepticism towards retractions post-conviction and highlighting inconsistencies between the affidavit and medical evidence.
**Doctrine:** The Supreme Court reiterates two doctrines: 1) petitions for review on certiorari shall only raise questions of law, not of fact, and 2) affidavits of recantation are viewed with disfavor and are not grounds for automatic reversal of a conviction, especially when derived post-conviction.
**Class Notes:**
– **Questions of Law vs. Questions of Fact:** A question of law exists when there is doubt as to what the law is on a certain set of facts. A question of fact exists when there is doubt about the truth or falsity of alleged facts.
– **Role of Appellate Courts in Witness Credibility:** Appellate courts generally do not disturb the trial court’s findings on witness credibility unless there are exceptional circumstances.
– **Doctrine on Affidavits of Desistance:** Affidavits of desistance or recantation by witnesses or complainants after conviction are generally viewed with disfavor and do not automatically result in acquittal, especially absent other compelling evidence.
**Historical Background:** In Philippine jurisprudence, the case highlights the complexities in dealing with recantations and the distinctions between questions of law and fact in the appellate process. The Supreme Court’s decision reiterates established legal principles on the appraisal of evidence, the finality of factual findings by trial courts, and the cautious approach towards affidavits of desistance.
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