Court of Appeals once again writes decision in Filipino

MANILA, Philippines — The Court of Appeals issued another criminal case decision entirely in Filipino on Dec. 30, 2024, a departure from the traditional use of English in judicial proceedings. 

This was done in an 11-page decision penned by Court of Appeals Associate Justice Apolinario Bruselas Jr., which upheld the conviction of homicide against the appellant.

The appellate court explained that the decision was written in Filipino to ensure that the accused, who testified in Filipino, could fully understand the ruling.

However, this is not the first time the appellate court has issued a decision in Filipino.

In 2022, the Court of Appeals also issued a criminal case decision in Filipino, which was also penned by Bruselas.

The case

The case is an appeal of a homicide conviction. The accused challenged the decision of the Calamba Regional Trial Court.

During the proceedings in the lower court, the appellate court stated that the accused faced the accusers and cross-examined them.

“Tanging ang nasasakdal ang humarap upang usisain ang mga testigo ng taga-usig,” a portion of the ruling read.

The accused also asserted that he was acting in self-defense, preventing the victim from attacking him.

“Pinigilan lamang niya ang biktima na saktan  siya  kaya  naman  aksidenteng  nahampas  ng  cabra  ang  biktima.  Wala din siyang ginawang masama upang himukin ang biktima na saktan siya,” a portion of the decision outlining the information against the accused read. 

(He merely stopped the victim from hurting him, which is why the victim was accidentally hit with the crowbar. He also did nothing wrong to provoke the victim into harming him.)

The decision

The appellate court affirmed the homicide conviction, saying that the accused's testimonies did not align with the medical findings, and that the testimony of the witness against him was consistent.

“Hindi tumpak ang sinasabi ng nasasakdal na nangyari sa kalagayan ng biktima at ang naging sanhi ng kaniyang kamatayan,” the court’s decision read.

(The accused's account of the events leading to the victim's death is inaccurate.)

“Pangalawa,malinaw sa salaysay ng saksi sa mga kaganapan na si [witness], ang ginawang pagpatay ng nasasakdal. Hindi pabago-bago ang kaniyang salaysay sa hukuman at sa pulisya,” it added. 

(Second, the testimony of eyewitness [witness] clearly establishes the accused's guilt. His account before the court and the police is consistent.)

The Court of Appeals emphasized that trial courts are best positioned to assess witness credibility due to their ability to observe witnesses firsthand. 

To reverse a trial court's credibility determination, the Court of Appeals explained that the appellant must demonstrate a clear error or prove that the decision was arbitrary. In the absence of any significant overlooked evidence, the trial court's findings will be upheld.

“Walang naipakitang sapat na kadahilanan ang nasasakdal upang baliktarin ang pagtatasa ng hukumang naglitis. Ang mga nabanggit niyang diumano’y mahirap unawain at hindi kapanipaniwala sa salaysay ni [witness] ay hindi sapat upang baguhin ang hatol ng hukumang naglitis,” the court’s decision read. 

(The accused has failed to present sufficient grounds to reverse the trial court's assessment. His arguments regarding the alleged inconsistencies and implausibilities in [witness]'s testimony are insufficient to overturn the trial court's judgment.)

Despite upholding the conviction, the appellate court reduced the accused's sentence from eight years and one day of prision mayor to 14 years, eight months, and one day of reclusion temporal.