People v. Tan, Jr.
REITERATIONFacts
The Antecedents: On May 13, 1977, Nestor Navarro went to collect a debt from Manuel Tan, Jr. Tan, Jr. and Hector Selmo were drinking. They invited Navarro to join them. Tan, Jr. decided to sell an LPG tank, and Selmo found a Ford Fiera driven by the victim, Mariano de Guzman, Jr. After selling the tank, the group, including the victim, went drinking in Guagua, Pampanga. The victim waited in the jeepney. Later, they went to Angeles City and then decided to return to San Fernando, Pampanga. During the trip back, Selmo directed Navarro to switch seats with him. Selmo then instructed the victim to turn onto a narrow road leading to an open field. Tan, Jr. told Navarro he would deal with the victim. When they stopped, Selmo handed a .45 caliber pistol to Tan, Jr. Tan, Jr. repeatedly struck the victim's head with the pistol, ignoring pleas for mercy. Tan, Jr. then shot the victim in the head, killing him instantly. The trio left the victim in a sugar cane field. They then proceeded to Manila, then Naga City where they sold three tires of the jeep, and eventually returned to Pampanga. Navarro and Tan, Jr. were apprehended in Masinloc, Zambales. Procedural History: The Court of First Instance of Pampanga convicted Manuel Tan, Jr. and Hector Selmo of Robbery with Homicide and sentenced them to death, ordering them to pay jointly and severally P12,000.00 and P6,577.00 and costs to the heirs of Mariano de Guzman, Jr. Co-accused Nestor Navarro pleaded guilty and was sentenced accordingly. The appellants interposed the present appeal. The Petition: The accused-appellants appealed the decision of the trial court.
Issue(s)
Whether the trial court erred in convicting the appellants based on the testimony of Nestor Navarro. Whether the defense of alibi presented by the appellants is sufficient to overcome the prosecution's evidence. Whether the physical and medical findings corroborate the testimony of Nestor Navarro. Whether proof of motive is necessary for conviction in a charge of Robbery with Homicide.
Ruling
The judgment of conviction is affirmed, but the penalty is reduced to reclusion perpetua, and the indemnity for the heirs is increased from P2,000.00 to P30,000.00.
Ratio Decidendi
On the conviction based on Nestor Navarro's testimony: The Court found no plausible reason to doubt the credibility of Nestor Navarro's testimony, which was anchored on his categorical declarations that Hector Selmo urged Manuel Tan, Jr. to kill the driver, and that Tan, Jr. subsequently struck and shot the victim. The Court held that witnesses are weighed, not numbered, and the testimony of a single credible witness, if positive, is sufficient for conviction. Navarro's narration of events was deemed natural, probable, and possessed the earmarks of truth, detailing the sequence of events and the appellants' behavior from their return to San Fernando. The Court emphasized that the trial judge's conclusions on credibility, supported by evidence, command great respect. On the defense of alibi: The Court reiterated that alibi is a weak defense, especially when faced with positive identification by a credible witness. The alibi presented by the appellants, which corroborated each other, was considered self-serving and untenable, especially since they were co-accused with a common defense. The Court found that the alibi dwindled into nothingness in the face of Nestor Navarro's positive identification of the appellants as the perpetrators. On the corroboration by physical and medical findings: The Court found that the physical and medical findings on the victim's body corroborated Nestor Navarro's testimony. Specifically, the Necropsy Report indicated that the victim died of shock secondary to cerebral hemorrhage due to a gunshot wound, and that abrasions and contusions were consistent with being struck by a rough object, possibly a gun. The lacerated wound on the occipital region could also be due to a blow from a gun. The recovery of the stolen jeep, albeit with missing tires, also served as corroboration. On the necessity of proving motive: The Court held that proof of motive is unessential for conviction when there is no doubt as to the identities of the perpetrators of the crime. The Court cited previous rulings in People v. Madera and People v. Guba to support this principle. The primary focus was on establishing the commission of the crime and the identity of the offenders, which was sufficiently achieved through Navarro's testimony and the physical evidence.
Main Doctrine
The testimony of a single credible witness, if positive and corroborated by physical and medical findings, is sufficient to convict, even against a defense of alibi. Proof of motive is not essential when the identity of the perpetrators is established.