People v. Guevarra
REITERATIONFacts
The Antecedents: At approximately 8:00 to 9:00 PM on March 12, 1969, in barrio Batasan, San Miguel, Bulacan, Lorenzo Manuzon was in his house with his wife Honorata Sevilla Manuzon, their mother, maid, and four children. Lorenzo had given his wife P80.00, the day's earnings from their jeep and jeepneys, which she placed in her pocket. While Lorenzo was lying down, he heard a thud, footsteps, and a demand for money. He saw co-accused Eduardo Catindihan and Eduardo Duria, armed with carbines, pushing his wife towards the room where he was. Upon reaching the door, his wife was shot and fell. Catindihan then fired his carbine at Lorenzo, who fell from the bed. From under the bed, Lorenzo saw co-accused Eduardo Agujo in the sala holding his daughter and a .45 caliber pistol. Agujo fired at Lorenzo but hit the crib. Catindihan and Duria were still in the sala. Duria and Agujo escaped, followed by Catindihan. After Catindihan left, Lorenzo pursued him to the balcony and was fired upon by appellant Domingo Guevarra with a Garand rifle from the foot of the stairs, but missed. Lorenzo returned to the room where his wife was unconscious with wounds to her left palm and left chest. He took her to the San Miguel Emergency Hospital, where he discovered the P80.00 was missing from her pocket. Due to her serious condition, she was transferred to the Philippine General Hospital, where she died during surgery. At the time of her death, she was a public school teacher and over five months pregnant. Procedural History: Appellant Domingo Guevarra, along with three other persons, was charged with robbery in band with homicide and frustrated homicide. He was convicted by the Circuit Criminal Court of the Fifth Judicial District, Malolos, Bulacan, and sentenced to death, with civil and moral damages. The case was elevated to the Supreme Court for automatic review due to the death penalty. Co-accused Eduardo Catindihan had previously been convicted and sentenced to death in an earlier trial. Eduardo Duria and Eduardo Agujo remained at large. The Petition: Appellant alleged that the trial court erred in basing its decision on the uncorroborated, inherently improbable, and inconsistent testimony of a lone witness, Lorenzo Manuzon. He also contended that the findings of fact were unsupported by evidence, that the defense's evidence was not given credence, and that his guilt was not established beyond reasonable doubt. He argued that his defense of alibi was erroneously disregarded.
Issue(s)
Whether the testimony of a lone witness, Lorenzo Manuzon, was sufficient to establish the guilt of the appellant beyond reasonable doubt, despite alleged inconsistencies and omissions. Whether the appellant's defense of alibi was credible and should have been given credence. Whether the appellant's flight and attempted escape were indicative of guilt. Whether conspiracy was established among the accused. Whether the aggravating circumstances were properly considered in imposing the death penalty.
Ruling
The Supreme Court affirmed the judgment of the trial court in all respects, including the imposition of the death penalty. The Court found the evidence sufficient to prove the appellant's guilt beyond reasonable doubt.
Ratio Decidendi
On the sufficiency of the lone witness's testimony: The Court held that the testimony of Lorenzo Manuzon, while uncorroborated in some aspects, was sufficient to establish the appellant's guilt. The alleged inconsistencies and omissions in his statement were satisfactorily explained by his fear of reprisal due to the appellant's father being a policeman at the time, and the psychological stress he experienced after witnessing the crime. The Court reiterated that fear of reprisal and emotional stress are valid excuses for a witness's momentary silence or failure to relate all details. The Court found no motive for Lorenzo Manuzon to falsely implicate the appellant, especially considering the appellant's father's position. On the defense of alibi: The Court found the appellant's alibi to be weak and inherently improbable. The appellant claimed to be within hearing distance of the crime, and the person he allegedly was with was not presented to corroborate his whereabouts. The Court emphasized that a weak alibi cannot outweigh positive identification by a credible witness. The appellant's actions after the crime, including his flight and attempted escape, further undermined his defense of alibi. On flight as an indication of guilt: The Court held that the appellant's actions after the commission of the crime, such as leaving his barrio, returning surreptitiously after more than a year, hiding in an aunt's house instead of his father's, and attempting to jump out of a window to avoid arrest, were clear indications of a guilty mind. Such flight is considered evidence of guilt, as it demonstrates an effort to evade apprehension and justice. The Court cited several cases to support the principle that flight is indicative of a guilty conscience. On conspiracy: The Court found that a conspiracy existed among the four accused, including the appellant. The appellant's presence at the scene of the crime with an assigned role as a lookout downstairs, evidenced by his firing at Lorenzo Manuzon when the latter pursued the other accused, demonstrated a concert of criminal design and a common objective. The Court held that in conspiracy, the act of one is the act of all, making each conspirator liable as a co-principal. On aggravating circumstances: The Court affirmed the trial court's finding of aggravating circumstances, namely nighttime, band, superior strength, and dwelling, without any mitigating circumstances. The Court noted that the presence of these aggravating circumstances was fully supported by the evidence and was not disputed by the appellant. These circumstances justified the imposition of the extreme penalty of death.
Main Doctrine
The flight of an accused, his surreptitious return to his barrio after more than a year's absence, living not in his father's house but in that of an aunt, and his attempted escape when his arrest was imminent, lend credence to the testimony of the state witness and are indicative of a guilty mind, rendering his defense of alibi unavailing.