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Nov 8, 1991 | Feliciano, J. | Petition for Certiorari | Exceptions to Hearsay Dying Declaration
PETITIONER: People of PH
RESPONDENT: Pioquinto de Joya
SUMMARY: Eulalia was stabbed to death. Her grandson found her and asked her what happened, to which she replied, Si Paqui
(de Joyas nickname). RTC convicted de Joya based on this dying declaration and other circumstantial evidence. SC Aquitted him
because this dying declaration was incomplete.
DOCTRINE: Doctrine of Completeness: A dying declaration to be admissible must be complete in itself. To be complete in itself
does not mean that the declarant must recite everything that constituted the res gestae of the subject of his statement, but that his
statement of any given fact should be a full expression of all that he intended to say as conveying his meaning in respect of such
fact.
FACTS:
Corcumstantial evidence:
ISSUE/RATIO
W/N Eulalias dying statement can be considered
as a dying declaration naming de Joya as her
killer. NO
ACQUITTED.