People v. Canada
REITERATIONFacts
The Antecedents: On June 8, 1979, in Davao City, accused Noli Dondoy and William Canada allegedly conspired and confederated to kill Manuel R. Pasaol. The information alleged that they attacked and stabbed the victim with a knife, inflicting injuries that caused his death. The prosecution presented Henry Cabrera, who testified that he was with the victim when William Canada called the victim. While Canada placed his arm on the victim's shoulder, Noli Dondoy pinned the victim's arms, and Canada then stabbed the victim on the right side of his stomach. The victim fell, and Cabrera brought him to the hospital where he died. Dr. Juanito Padilla, who performed the autopsy, confirmed the stab wound on the liver and massive hemoperitoneum, stating the victim died due to massive loss of blood. Remedios Salingay identified the victim's death certificate. Procedural History: The then Court of First Instance of Davao found Noli Dondoy and William Canada guilty beyond reasonable doubt of Murder. Noli Dondoy was sentenced to suffer Reclusion Perpetua and to indemnify the heirs of the deceased. William Canada, being a minor, was given a lesser penalty and committed to the custody of the Ministry of Social Services and Development until he reached 21 years of age. William Canada did not appeal. The Petition: Appellant Noli Dondoy appealed the decision, raising errors concerning the lower court's reliance on the uncorroborated testimony of the sole eyewitness, the alleged contradiction between the eyewitness's testimony and the autopsy findings, and the failure to acquit him based on reasonable doubt.
Issue(s)
Whether the lower court erred in giving full credence to the uncorroborated testimony of the eyewitness, Henry Cabrera. Whether the lower court erred in brushing aside the testimony of the barrio captain which allegedly contradicted the eyewitness's claim. Whether the lower court erred in not acquitting the accused-appellant on the basis of reasonable doubt.
Ruling
The Supreme Court affirmed the decision of the lower court finding Noli Dondoy guilty of Murder, with the modification of increasing the indemnity to P30,000.00.
Ratio Decidendi
On the credibility of the eyewitness: The Court held that there is no law requiring the testimony of a single witness to be corroborated, except in specific cases like treason. The credibility of witnesses is weighed, not numbered, and a single credible and positive witness is sufficient for conviction. The Court deferred to the trial court's findings of fact, as it had the opportunity to observe the witness's demeanor. The alleged inconsistency between Cabrera's testimony that Dondoy pinned the victim's arms and the autopsy finding of wounds on the victim's hands was deemed a minor detail that did not affect the integrity of Cabrera's testimony. The Court reasoned that the victim's hands could have reached out for the knife even if his arms were pinned, and such minor discrepancies can even add credence to a spontaneous testimony. The Court cited People v. Alcantara for the principle that trivial contradictions do not impair credibility and may demonstrate good faith. On the barrio captain's testimony: The Court found no merit in the contention that the barrio captain's testimony should have been given more weight. The mere fact that Cabrera was a friend of the victim did not automatically prove prejudice sufficient to disregard his testimony. The Court has consistently upheld testimonies of relatives, and in the absence of improper motive, their natural interest in serving justice deters them from implicating innocent persons. The Court noted that the barrio captain's testimony about seeing Cabrera at a store reading comics did not make it impossible for Cabrera to be at the scene of the crime, as it occurred on the same street. On reasonable doubt and alibi: The Court reiterated that against positive identification by a witness, alibi is unavailing. For alibi to be accepted, the accused must demonstrate that it was physically impossible for him to be at the scene of the crime. The Court found that the defense failed to present other witnesses who could have exculpated the accused, despite the scene being well-lit. The Court concluded that the trial court did not err in finding appellant Dondoy guilty beyond reasonable doubt, as Cabrera clearly and positively identified Dondoy's participation in the crime, and Dondoy's denial could not overcome this evidence.
Main Doctrine
The testimony of a single witness, if credible and positive, is sufficient to convict, and inconsistencies on minor details do not affect credibility as they refer to collateral matters. Against positive identification, alibi is unavailing.