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    People v. Salafranca

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    azuremango
    1. Rodrigo Salafranca was convicted of murdering Johnny Bolanon by fatally stabbing him. 2. As Bolanon was being rushed to the hospital, he told his uncle Estao that Salafranca was his attacker. 3. The Supreme Court affirmed the conviction, finding that Bolanon's statement qualified as a dying declaration and was also part of the res gestae, both exceptions to the hearsay rule.

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    People v. Salafranca

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    azuremango
    189 views2 pages
    1. Rodrigo Salafranca was convicted of murdering Johnny Bolanon by fatally stabbing him. 2. As Bolanon was being rushed to the hospital, he told his uncle Estao that Salafranca was his attacker. 3. The Supreme Court affirmed the conviction, finding that Bolanon's statement qualified as a dying declaration and was also part of the res gestae, both exceptions to the hearsay rule.

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    1. Rodrigo Salafranca was convicted of murdering Johnny Bolanon by fatally stabbing him. 2. As Bolanon was being rushed to the hospital, he told his uncle Estao that Salafranca was his attacker. 3. The Supreme Court affirmed the conviction, finding that Bolanon's statement qualified as a dying declaration and was also part of the res gestae, both exceptions to the hearsay rule.

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    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    189 views2 pages

    People v. Salafranca

    Uploaded by

    azuremango
    1. Rodrigo Salafranca was convicted of murdering Johnny Bolanon by fatally stabbing him. 2. As Bolanon was being rushed to the hospital, he told his uncle Estao that Salafranca was his attacker. 3. The Supreme Court affirmed the conviction, finding that Bolanon's statement qualified as a dying declaration and was also part of the res gestae, both exceptions to the hearsay rule.

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    PEOPLE v.

    SALAFRANCA
    February 22, 2012 | GR No. 173476 | Bersamin, J. | Hearsay Rule - Exceptions - Dying Declaration

    PLAINTIFF-APPELLEE: People of the Philippines


    DEFENDANT-APPELLANT: Rodrigo B. Salafranca
    SUMMARY: Salafranca fatally stabbed Bolanon. Bolanon sought help from his uncle, Estao. On the way to the
    hospital in a taxi, Estao asked Bolanon who stabbed him, Bolanon answered that it was Salafranca. When they got to
    the hospital, Salafranca was pronounced dead 10 minutes later. RTC, CA and SC all affirmed the conviction of
    Salafranca as guilty of murder. SC found that Bolanon's dying declaration in the taxi en route to the hospital was
    admissible as evidence because it met all the requisites of a valid dying declaration.
    GENERAL RULE: A dying declaration is generally inadmissible as evidence due to its hearsay character.
    EXCEPTION: When the ff. requisites concur:
    (a) The declaration must concern the cause and surrounding circumstances of the declarant's death;
    (b) That at the time the declaration is made, the declarant is under a consciousness of an impending death;
    (c) That the declarant is a competent witness;
    (d) That the declaration is offered in a criminal case for homicide, murder, or parricide, in which the declarant is a
    victim.

    FACTS: 2. SC held that the circumstances (underlined and in


    1. On July 31, 1993, Johnny Bolanon was stabbed near a bold in Fact #3) qualified Bolanon's utterance as both a
    sports complex in Binondo. Bolanon was stabbed by his dying declaration and as part of the res gestae, which are
    attacker by grabbing Bolanon's neck from behind and both exceptions to the hearsay rule.
    delivering the stabbing blow towards Bolanon's chest. 3. DYING DECLARATION
    2. The incident was witnessed by a 13 year old minor, GENERAL RULE: Inadmissible as evidence due to its
    Augusto Mendoza. His attacker ran away. hearsay character.
    3. After the stabbing incident, Bolanon was still able to EXCEPTION:If the following requisites concur:
    walk to the house of his uncle, Rodolfo Estao, in order to
    seek help. Estao rushed Bolanon to the Philippine REQUISITES: AS APPLIED IN THIS
    General Hospital (PGH) in a taxi. On the way there, DYING CASE
    Bolanon told Estao that it was defendant Salafranca DECLARATION
    who had stabbed him. Bolanon was suffering from a (a) Declaration must Bolanon communicated his
    hard time breathing, so Estao told him not to talk concern the cause and anti-mortem statement to
    anymore because he will just suffer more. 10 minutes surrounding circumstances Estao, identifying
    after they got to the ER, Salafranca died. of the declarant's death Salafranca as the one who
    4. Salafranca fled after stabbing Bolanon, evading arrest stabbed him
    for nearly 10 years. He was arrested on April 23, 2003. (b) That at the time the At the time of his
    5. RTC convicted Salafranca for murder for the fatal declaration is made, the statement, Bolanon was
    stabbing of Bolanon. This was confirmed by the CA. declarant is under a conscious of his
    Hence this appeal. consciousness of an impending death because
    impending death; of his stab wound in the
    ISSUE RELEVANT TO OUR CLASS: WON chest, was experiencing a
    Salfranca is guilty of Bolanon's murder? YES. hard time breathing, and
    died in the ER
    RULING: CA decision affirmed. (c) That the declarant is a Bolanon would've been
    competent witness; competent to testify on his
    RATIO: declaration had he
    1. The SC noted Rodolfo Estao's testimony (Bolanon's survived
    uncle) that identified Salafranca as his assailant after the (d) That the declaration is Dying declaration offered
    stabbing happened. Estao testified that while they were offered in a criminal case in this criminal
    traveling to PGH, Estao asked who stabbed Bolanon and for homicide, murder, or prosecution for Bolanon's
    Bolanon answered that it was Rod Salafranca, the parricide, in which the MURDER
    defendant, who had stabbed him. declarant is a victim.
    During the trial, Salafranca was positively *SECOND PAGE IS NOT GERMANE TO OUR DISCUSSION AS
    identified by Estao as the person who Bolanon TO DYING DECLARATION BUT IS RELEVANT AS TO THE
    said stabbed him before he died. TOPIC IN CLASS, SO VALID YUNG SECOND PAGE KO. :P
    4. RES GESTAE = Circumstances which are the
    undesigned incidents of a particular litigated act and
    which are admissible when illustrative of such act.
    Generally, it referes to the circumstances, facts, and
    declarations that grow out of the main fact and serve to
    illustrate its character and are so spontaneous and
    contemporaneous with the main fact as to exclude the
    idea of deliberation and fabrication.
    The rule on res gestae encompasses the
    exclamations and statements made by either the
    participants, victims, or spectators to a crime
    immediately before, during, or immediately after
    the commission of the crime when the
    circumstances are such that the statements were
    made as a spontaneous reaction or utterance
    inspired by the excitement of the occasion and
    there was no opportunity for the declarant to
    deliberate and to fabricate a false statement.
    Test of admissibility of evidence as a part of the
    res gestae: Whether the act, declaration, or
    exclamation is so intimately interwoven or
    connected with the principal fact or event that it
    characterizes as to be regarded as a part of the
    transaction itself, and also whether it clearly
    negatives any premeditation or purpose to
    manufacture testimony.

    REQUISITES: AS APPLIED IN THIS


    RES GESTAE CASE

    (a) Principal act (res The startling occurerence


    gestae) is a startling was the stabbing itself
    occurrence

    (b) Statements are made Bolanon was in the taxi on


    before the declarant had the way to PGH and had
    time to contrive or devise no time to contrive his
    identification of Salafranca
    as the assailant

    (c) Statements must Dying declaration was


    concern the occurrence in made in spontaneity and
    question and its only in reaction to the
    immediately attending stabbing. It's relevant
    circumstances because it identified
    Salafranca as the murderer

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