People v. Datahan
REITERATIONFacts
The Antecedents: On July 15, 1984, Vedasto Piscos was attacked by two men, Tito Datahan and Cenen Coscos, who struck him, causing him to run and fall unconscious. His house was subsequently burned, and his wife, Librada Piscos, died in the fire. Vedasto identified his assailants. Procedural History: Separate informations for robbery with homicide, frustrated homicide, and arson were filed against five individuals. Two were acquitted of all charges. The accused-appellants, Tito Datahan and Cenen Coscos, were acquitted of robbery with homicide but convicted of frustrated homicide and arson. The trial court imposed the death penalty for arson. The Petition: The accused-appellants challenged their conviction, arguing that the trial court erred in discrediting their alibis and admitting the testimony of prosecution witnesses Vedasto Piscos and Rolando Betonio, claiming inconsistency and bias, respectively.
Issue(s)
Whether the trial court erred in not giving credence to the alibis of the accused-appellants. Whether the testimony of Vedasto Piscos was credible despite alleged inconsistencies. Whether the testimony of Rolando Betonio was credible despite alleged bias. Whether the circumstantial evidence was sufficient to establish the guilt of the accused-appellants for arson. Whether there was conspiracy between Tito Datahan and Cenen Coscos.
Ruling
The appealed judgment is AFFIRMED as modified, with the death sentence for arson reduced to reclusion perpetua in accordance with the new Constitution. The conviction for frustrated homicide and arson stands.
Ratio Decidendi
On the alibi of the accused-appellants: Alibi is an inherently weak defense and must fail in the face of positive identification by the victim and eyewitnesses. The testimonies of Vedasto Piscos and Rolando Betonio positively identified Tito Datahan and Cenen Coscos. The accused-appellants' claims of being elsewhere were unsubstantiated and contradicted by prosecution witnesses. The Court found no reason to doubt the positive identification made by the victim, who had known the accused for twenty years, and by Rolando Betonio, who saw them near the scene of the crime. On the credibility of Vedasto Piscos' testimony: While there were inconsistencies in Vedasto Piscos' declarations, they did not detract from the credibility of his testimony in its totality. The witness was 72 years old when he testified about events that occurred almost a year prior. Despite not recalling every detail, his identification of the assailants was clear and unwavering. The Court emphasized that minor inconsistencies in the testimony of a witness, especially considering the passage of time and the traumatic nature of the event, do not necessarily impair the credibility of the witness regarding the main facts. On the credibility of Rolando Betonio's testimony: The defense's contention that Rolando Betonio's testimony was biased due to a prior altercation with Leoncio Datahan was noted but did not render his testimony incredible. Betonio's account of seeing Tito Datahan and Cenen Coscos hiding behind a dike while the house was burning corroborated Vedasto Piscos' testimony regarding their presence and involvement. The Court found that Betonio's testimony, when considered with other evidence, was consistent and reliable. On the sufficiency of circumstantial evidence for arson: Although there was no direct evidence linking the accused-appellants to the arson, the Court found them guilty based on several revealing circumstances. These included Vedasto Piscos being assaulted by Datahan and Coscos, the house burning while he was unconscious, the accused-appellants being seen watching the fire, and the discovery of the victim's charred remains. The close connection between the assault on Vedasto and the subsequent burning of the house led to the inevitable conclusion that the assailants were the perpetrators of the arson and homicide. On the existence of conspiracy: The Court found conspiracy between Tito Datahan and Cenen Coscos, evidenced by their concert of action and community of design. They were together when Vedasto Piscos was attacked, and they were seen together watching the fire. If Coscos had not been a conspirator, he would have likely assisted Vedasto or left the scene instead of remaining with Datahan and observing the burning house. Their continued presence together indicated their shared intent and participation in the commission of the crimes.
Main Doctrine
Alibi is an inherently weak defense and will be rejected in the face of positive identification. Conspiracy may be inferred from the concert of action and community of design among the accused.