Cordial v. People
REITERATIONFacts
The Antecedents: On August 23, 1981, C2C Emmanuel Romero and Nicanor Lanuza were riding a passenger jeep. The jeep stopped to unload passengers. Petitioner Bernardo M. Cordial, armed with an 'improvised knife,' entered the jeep and stabbed Romero. Cordial's companions then disarmed Romero and Lanuza of their armalite rifles and stabbed Lanuza multiple times. Romero died on the spot from multiple gunshot and stab wounds. Cordial was arrested eight months later and investigated, but refused to sign his statement. Procedural History: The prosecution filed a complaint for murder. After preliminary investigation, an information for murder was filed against Cordial. The Regional Trial Court (RTC) found Cordial guilty of homicide, not murder, as treachery and evident premeditation were not proven. The RTC imposed an indeterminate sentence and ordered indemnity. The Court of Appeals (CA) affirmed the RTC decision but increased the indemnity to P30,000. The Petition: Cordial filed a petition for review on certiorari, challenging the credibility of the sole eyewitness, Nicanor Lanuza, and arguing that the attack was not sudden, and that Lanuza's testimony was inherently improbable.
Issue(s)
Whether the testimony of the sole eyewitness, Nicanor Lanuza, is credible. Whether the attack on the victim was sudden, negating the possibility of preparation or warning. Whether the petitioner's defense of alibi is sufficient to overcome the positive identification by the eyewitness. Whether the crime committed was homicide or murder.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, upholding the conviction of Bernardo M. Cordial for homicide. The Court found the testimony of the sole eyewitness, Nicanor Lanuza, to be credible and sufficient for conviction. The defense of alibi was found unavailing due to the positive identification by Lanuza, and the physical impossibility of Cordial being at the scene was not proven. The Court agreed with the lower courts that the crime committed was homicide, as the qualifying circumstances of treachery and evident premeditation were not sufficiently established.
Ratio Decidendi
On the credibility of Nicanor Lanuza: The Court held that the testimony of a single eyewitness, if credible and positive, is sufficient to convict. The petitioner's attempt to discredit Lanuza based on alleged participation in a 'rub-out' was unavailing, as it was based on uncorroborated testimony and hearsay, and impeachment of a witness must be directed at general character for truth and veracity, not particular wrongful acts. The Court reiterated that findings of the trial court on the credibility of witnesses are entitled to great weight. Even convicted criminals are not excluded from testifying, provided they can perceive and make known their perceptions. The Court found Lanuza's testimony to be consistent and natural on substantial matters, despite minor variances in his reckoning of time or apparent confusion during cross-examination, which were considered indicative of an unrehearsed account rather than prevarication. The fact that Lanuza was the sole eyewitness was deemed immaterial, as there is no law requiring corroboration for a single credible witness's testimony. On the suddenness of the attack: The Court found that the lapse of time between Lanuza seeing Cordial's group and the actual attack was not sufficient to negate the suddenness of the assault. Lanuza testified that despite knowing an attack was imminent, the assault was so sudden that he had no time to prepare or warn the victim. The Court considered Lanuza's apparent mis-estimation of time as trivial and immaterial to his overall credibility. The Court also addressed the apparent confusion in Lanuza's testimony regarding whether Cordial was seated or standing when he stabbed Romero, explaining that this was likely due to the 'rumble' during the assault and did not necessarily indicate prevarication, but rather an unrehearsed account. On the defense of alibi: The Court ruled that the defense of alibi was unavailing because Cordial was positively identified by Lanuza, who had no proven motive to falsely accuse Cordial. Furthermore, the defense failed to prove that it was physically impossible for Cordial to have been at the scene of the crime. Cordial's admission that Sundays were generally rest days, except for specific tasks, and that the crime scene was adjacent to where his parents resided, made his alibi weak and unconvincing. The Court emphasized that alibi must be substantiated by positive proof of physical impossibility to be at the scene of the crime. On the crime committed (homicide vs. murder): The Court agreed with the lower courts that the crime committed was homicide, not murder. This was because the qualifying circumstances of treachery and evident premeditation, which would elevate the crime to murder, were not sufficiently proven by the prosecution. The Court noted that the RTC found no aggravating or mitigating circumstances, leading to the imposition of the penalty for homicide under Article 249 of the Revised Penal Code. The appellate court's modification was limited to increasing the indemnity, not the classification of the crime.
Main Doctrine
The testimony of a single eyewitness, if credible and positive, is sufficient to convict, and minor variances in the testimony do not necessarily impair credibility, especially when corroborated by physical evidence. The defense of alibi is unavailing when the accused is positively identified by a credible witness and it is not physically impossible for the accused to have been at the scene of the crime.