Facts:
Charlon was convicted of carnapping by the RTC. On appeal to the Court of Appeals, the latter affirmed the RTC decision. Charlon thus filed a Motion for New Trial, alleging that the main witness had executed his Salaysan ng Pag-Uurong, which he attached to his motion, and which he alleged, if admitted, may reverse his conviction for carnapping. The CA denied the motion, holding that the Salaysay is an affidavit of recantation after conviction, which it did not find sufficient ground for a new trial, absent any other newly discovered evidence. Thus, Charlon filed the instant petition before the Supreme Court, alleging that the CA committed grave abuse of discretion when it denied his Motion for New Trial on account of the said recantation.
Issue:
Whether or not the Affidavit of Recantation should be admitted and new trial granted to Charlon on the basis of the Affidavit.
Ruling:
Petition granted.
For the recantation of a witness to constitute ground for new trial, it must be shown that: (1) the testimony of the retracting witness during trial is essential to the judgment of conviction such that its elimination would lead the trial judge to a different conclusion; (2) there exists special circumstances which, coupled with the retraction, raise doubt as to the testimony given by the retracting witness at the trial; and (3) there is no other evidence sustaining the judgment of conviction except said testimony.
CHARLON FERNANDO y ESMA v. PEOPLE OF THE PHILIPPINES, G.R. No. 259589, July 29, 2025