People v. Encipido
REITERATIONFacts
1. The Antecedents: The case concerns the brutal murder of Jose Lacumbes, whose body was discovered on March 30, 1982, with severe neck wounds, multiple stab wounds, and his hands tied behind his back. The post-mortem examination revealed the cause of death to be severe hemorrhage resulting from these injuries, with the additional gruesome detail of his right ear being removed. The victim was a resident of Barangay Mabini in Tubajon, Surigao del Norte, and was found near his farm hut. 2. Procedural History: Eight individuals were initially charged with murder in Criminal Case No. 14 before the Regional Trial Court, 10th Judicial Region, Branch 32. However, only three accused-appellants, Brigido Encipido, Charlito Manatad, and Eddie de la Peña, proceeded to trial as the others remained at large. The trial court found the appellants guilty of Murder and sentenced them to reclusion perpetua, along with damages and costs. A motion for reconsideration filed by the appellants' counsel was denied for being filed out of time. Subsequently, an appeal was lodged with the Intermediate Appellate Court, which was then indorsed to the Supreme Court due to the penalty imposed. 3. The Petition: The accused-appellants raised several assignments of error before the Supreme Court, primarily challenging the lower court's reliance on hearsay testimonies, the credibility of the eyewitness Felicisimo Alciso, the appreciation of Eddie de la Peña's judicial admission against his co-accused, and their overall conviction. They also contested the denial of their motion for reconsideration. The Supreme Court reviewed the evidence, including eyewitness accounts, extrajudicial confessions, and judicial admissions, to determine the guilt of the appellants beyond reasonable doubt.
Issue(s)
Whether the testimonies of prosecution witnesses, particularly Felicisimo Alciso, Jorge Ortega, and Mariano Espina, were credible and admissible. Whether the extrajudicial oral confessions made by Brigido Encipido and Eddie de la Peña to Station Commander Ortega and Municipal Mayor Espina, and the judicial admission of Eddie de la Peña in open court, were admissible and sufficient to convict the appellants. Whether the defense of alibi interposed by Brigido Encipido and Charlito Manatad was sufficient to overcome the prosecution's evidence. Whether the lower court erred in denying the motion for reconsideration filed by the appellants.
Ruling
The Supreme Court affirmed the conviction of the appellants for Murder, sentencing them to reclusion perpetua. The civil indemnity was increased to P30,000.00. The Court found the evidence against the appellants to be sufficient for conviction beyond reasonable doubt.
Ratio Decidendi
On Issue 1: The Court found the testimony of eyewitness Felicisimo Alciso to be credible. Despite initial statements of not recognizing the assailants during the mauling, Alciso later positively identified the appellants as those involved in the killing, specifically noting Encipido's command and De la Peña's act of hacking the deceased's neck. The Court noted that Alciso's description of the injuries, including the incised wound on the neck and hands tied at the back, was corroborated by the autopsy findings. While Alciso's distance from the scene was questioned, the Court held that provincial folk's estimates of distance can be inexact, and the crucial fact was his witnessing the incident and identifying the malefactors. His subsequent visit to the jail to verify identities was deemed unusual but explained by his fear of reprisal, and his initial omission of names in his sworn statement was attributed to the circumstances of its taking. The testimonies of Station Commander Ortega and Municipal Mayor Espina regarding the appellants' admissions were also deemed admissible, not as hearsay, but as proof of oral confessions heard by competent witnesses. The Court found no proof of coercion, and the lack of immediate arrests was explained by the prevailing atmosphere of goodwill. On Issue 2: The Court held that the oral confessions made by Encipido and De la Peña to Station Commander Ortega and Municipal Mayor Espina, as well as De la Peña's judicial admission in open court, were admissible in evidence against them. These confessions were made voluntarily, without collusion, and were identical in material respects, thus falling under Sections 22 and 29 of the Rules of Court. The Court emphasized that these confessions were made against the declarants' own interests, giving them evidentiary value. Furthermore, these interlocking confessions served as corroborative evidence against their co-accused, implicating them in the commission of the crime. De la Peña's judicial admission, even with exculpatory statements, was considered a confession, and his claim of being forced to join the group was disproven by his own admissions and the eyewitness account, which were corroborated by autopsy findings. The Court also clarified that testimony given by a co-accused during trial, implicating others, is competent evidence against the latter, who have the right to cross-examine. On Issue 3: The defense of alibi interposed by Encipido and Manatad was found to be unavailing against their positive identification by the eyewitness, their own verbal acknowledgments of guilt, and De la Peña's interlocking confessions. The Court noted that the places where Encipido and Manatad claimed to be were geographically distant from the crime scene, making their alibis improbable. The Court reiterated that alibi cannot prevail over positive identification and confessions, especially when the accused failed to prove that it was physically impossible for them to have been at the scene of the crime at the time of its commission. On Issue 4: The Court found the issue regarding the denial of the motion for reconsideration to be of no consequence, as all the grounds raised in the motion had been elevated to and considered by the Supreme Court on appeal. The Court's review of the merits of the case rendered the procedural issue moot.
Main Doctrine
Extrajudicial confessions, whether oral or written, are admissible in evidence against the declarants, and when made independently without collusion and are identical in material respects, they can serve as corroborative evidence against co-accused. The credibility of an eyewitness, even with minor inconsistencies, is generally upheld if their testimony is consistent regarding the main incident and the identity of the malefactors, especially when corroborated by other evidence and autopsy findings. The findings of the trial court on the credibility of witnesses are entitled to great weight and should not be disturbed on appeal unless there is a clear showing of error.