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PEOPLE OF THE PHILIPPINES V FRANCISCO SANTOS

GR NO. 94545 April 4, 1997

Digested by: Shineth Divine D. Alejandre

FACTS:

Appellant was charged with murder. Prosecution presented witnesses Corazon


and Pedro Dayao and Lolita Ambre to testify on the circumstances of the crime.
Corazon Dayao stated that he saw David fall and seeing David wanted to say
something to Lolita, her wife. She pulled Lolita towards the victim. Lolita asked
her husband who had shot him and the latter answered, "It was Pare Pran." She
heard David's words because, like Lolita, she had also placed her head near David
who was still alive at the time. Lolita Ambre, testified as well that before her
husband died, she went near him, he said, "Pare Pran." She knew that her
husband was referring to Francisco Santos, the godfather of their youngest child.

ISSUE:

Whether the antemortem statement of the deceased identifying the accused


constitutes a dying declaration sufficient to sustain the conviction of appellant.

HELD:

Yes. A dying declaration is entitled to the highest credence because noperson who
knows of his impending death would make a careless and false accusation. As an
exception to the hearsay rule, the requisites for its admissibility are as follows:
(1) the declaration is made by the deceased under the consciousness of his
impending death; (2) the deceased was at the time competent as a witness; (3) the
declaration concerns the cause and surrounding circumstances of the declarant's
death; and (4) the declaration is offered in a criminal care wherein the declarant's
death is the subject of inquiry.

It must be shown that a dying declaration was made under a realization by the
decedent that his demise or at least, its imminence — not so much the rapid
eventuation of death — is at hand. This may be proven by the statement of the
deceased himself or it may be inferred from the nature and extent of the
decedent's wounds, or other relevant circumstances.

In the case at bar, the victim's declaration consisted of the words "Pare Pran."
Under the circumstances, however, he could not have been expected to articulate
his awareness of something so obvious — the inevitability of his demise — or to
have the energy to do so. The nature and extent of said injuries underscored the
seriousness of his condition and they later proved by themselves that the
utterances of the deceased were made under a consciousness of an impending
death. That his demise thereafter came swiftly, although not instantaneously,
further emphasized the victim's realization of the hopelessness of his recovery.

We stress that when a person is at the point of death, every motive for falsehood
is silenced and the mind is induced by the most powerful consideration to speak
the truth.