People v. Repato
REITERATIONFacts
The Antecedents: Jose Repato and Feliciano Natad were charged with Murder before the CFI of Pangasinan for the killing of Prudencio Vallo. The body of Vallo was found on the side of a barrio road with three bullet wounds and a crushed skull. Autopsy revealed multiple gunshot wounds. Five empty shells and three lead slugs were found near the body. The prosecution presented eyewitnesses who testified that on the evening of August 31, 1960, during a picnic, Jose Repato made a remark about Prudencio Vallo and then followed him with Feliciano Natad. Shortly after, gunshots were heard. One witness testified to seeing Repato carrying a carbine and firing at Vallo, and that Natad struck Vallo with a stone while Vallo was down. The witnesses also testified that Repato and Natad asked one of them to hide the carbine used in the killing, which was later recovered by authorities. Evidence showed the carbine was forcibly taken by Repato and Natad from its owner's guard prior to the incident. Procedural History: The CFI of Pangasinan found Jose Repato guilty of Murder, sentencing him to reclusion perpetua, and ordered him to indemnify the heirs of the deceased. Feliciano Natad was acquitted on reasonable doubt. Jose Repato appealed the decision. The Petition: The appellant, Jose Repato, contended that the lower court erred in lending credence to the State witnesses, in disregarding his defense of alibi, and in holding that his guilt was established beyond reasonable doubt.
Issue(s)
Whether the lower court erred in lending credence to the State witnesses. Whether the lower court erred in disregarding the defense of alibi. Whether the guilt of the appellant had been established beyond reasonable doubt.
Ruling
The Supreme Court affirmed the decision of the lower court in all respects, finding Jose Repato guilty of Murder. The sentence of reclusion perpetua, indemnity to the heirs of the deceased, and costs were upheld. Feliciano Natad's acquittal was also affirmed.
Ratio Decidendi
On the issue of lending credence to State witnesses: The Court held that the denial by the appellant of his presence at the picnic was of doubtful veracity and could not overcome the positive testimony of the eyewitnesses who saw and identified him during the killing. The settled rule is that negative evidence cannot overcome the State's positive proof, especially in the absence of adequate motive for the state witnesses to testify falsely against the accused. Even if a grudge were granted, it was not sufficient to prompt the witnesses to fabricate evidence and falsely implicate the appellant in so grave a crime as murder. The Court also noted that inconsistencies in the testimony of state witnesses, if not material and substantial, do not affect their credibility, and their initial reluctance to report the matter immediately to authorities is common and judicially declared not to affect credibility. On the issue of disregarding the defense of alibi: The Court found the appellant's defense of alibi to be unbelievable and effectively negated by other evidence. The appellant claimed to be in Manila looking for a job from August 5, 1960, until September 5, 1960. However, his first cousin testified that Repato was in Aguilar on the evening of the killing and passed his house on the way to Manila the following dawn. Furthermore, the testimony of Nora Ayeras, who claimed Repato was in Manila, was discredited because she herself was busy looking for a job and was not in a position to categorically state that the appellant was actually present in Manila to preclude his having gone to Aguilar. The Court reiterated that the defense of alibi requires the accused to be in a place where it is impossible for him to have committed the crime, and this was not met by the appellant's unsubstantiated claim. On the issue of whether guilt was established beyond reasonable doubt: The Court found that the guilt of the appellant was established beyond reasonable doubt. It was fully established that the appellant and his co-accused had forcibly taken the carbine used in the killing. Ballistic examination confirmed that the cartridges and slugs found at the scene and in the victim were fired from the same carbine. The appellant and Natad also attempted to have Macario hide the carbine immediately after the shooting, and it was hidden where peace officers retrieved it. The positive eyewitness accounts, corroborated by physical evidence and the failure of the alibi defense, collectively proved the appellant's culpability for the crime of murder.
Main Doctrine
The defense of alibi, which requires the accused to be in a place where it is impossible for him to have committed the crime, vanishes when contradicted by positive eyewitness testimony and other corroborating evidence, especially when the witnesses are known to the accused and have no apparent motive to fabricate testimony. Inconsistencies in witness testimony that are not material or substantial do not affect credibility, and initial reluctance to report a crime is common and does not diminish credibility.