People v. Acelajado
REITERATIONFacts
The Antecedents: On November 30, 1982, Herminigildo Caraan was eating lunch when Reynaldo Acelajado approached him and offered to sell marijuana. Caraan purchased one plastic bag of marijuana for P10.00. After eating, Caraan went to a movie theater, where he was frisked by Pat. Rolando Ambojia, who confiscated three rolls of marijuana cigarettes. Caraan was brought to the police headquarters, where he identified Reynaldo Acelajado as the seller. The confiscated specimens were confirmed by the NBI chemist to be marijuana. Procedural History: Reynaldo Acelajado was charged with violation of Section 4 of RA 6425, as amended. After trial, the Regional Trial Court found him guilty beyond reasonable doubt and sentenced him to suffer reclusion perpetua and to pay a fine of P20,000.00. The Petition: Accused-appellant Reynaldo Acelajado appealed the decision, assigning errors related to the lower court's acceptance and weight given to the testimony of Herminigildo Caraan, its failure to accept the defense that the accused was not in Siniloan, Laguna on the date of the incident, and its disregard of the testimonies of Barangay Captain Felix Paz and Police Station Commander Bartolome Jameto.
Issue(s)
Whether the lower court erred in accepting the confession and giving weight to the testimony of Herminigildo Caraan. Whether the lower court erred in not accepting the accused's alibi that he was not in Siniloan, Laguna on November 30, 1982. Whether the lower court erred in not giving credence to the testimonies of Barangay Captain Felix Paz and Police Station Commander Bartolome Jameto. Whether the testimony of Herminigildo Caraan was sufficient to establish the guilt of the accused beyond reasonable doubt.
Ruling
The decision of the Regional Trial Court is AFFIRMED. Costs against the appellant.
Ratio Decidendi
On the issue of credibility of witnesses and the acceptance of Herminigildo Caraan's testimony: The Supreme Court accords the highest degree of respect for the findings of the trial court on witness credibility. The trial court found no reason to doubt Herminigildo Caraan's credibility and no legal justification to disregard his testimony. There was no evidence of fabrication. The testimonies of defense witnesses, Station Commander Capt. Jamito and Barangay Captain Felix Paz, were hearsay and of no probative value. The Court found no error in accepting Caraan's testimony, as he positively identified the accused as the seller of marijuana, and his testimony was corroborated by the confiscation of marijuana and subsequent NBI analysis. On the defense of alibi: Alibi is inherently a weak defense. The accused failed to present corroborating evidence for his alibi. The weak and uncorroborated denial of the accused cannot prevail over the clear, positive, and straightforward testimony of the prosecution witness, Herminigildo Caraan. On the testimonies of Barangay Captain Felix Paz and Police Station Commander Bartolome Jameto: The uncorroborated testimonies of the defense witnesses, Station Commander Capt. Jamito and Barangay Captain Felix Paz, to the effect that Caraan implicated Acelajado for revenge were not given serious consideration because they were purely hearsay and of no probative value. Moreover, the omission to bring these matters out during Caraan's cross-examination raised a presumption that there was no truth to the defense witnesses' testimonies. On the sufficiency of Herminigildo Caraan's testimony: The testimony of Caraan, who identified the accused and recounted the transaction, was found to be credible and sufficient to establish the guilt of the accused beyond reasonable doubt. The Court found no basis to doubt the veracity of Caraan's statement, which was directly corroborated by the physical evidence and the subsequent police action.
Main Doctrine
The Supreme Court accords the highest degree of respect for the findings of the trial court on the issue of credibility of witnesses, as the trial court is in a better position to decide the question, having heard the witnesses and observed their deportment. Uncorroborated alibi is a weak defense that cannot prevail over clear, positive, and straightforward testimony of the prosecution witness. Hearsay testimonies, by their very nature, are of no probative value.