People v. Padilla
REITERATIONFacts
The Antecedents: The spouses Crisostomo Amarillo and Anita Galamgam, engaged in the buy and sell of gold, were on their way home with approximately P40,000.00 in cash and assorted jewelry. They were followed by Mateo Padilla, Boy Batin, and Benjamin Padilla. Mateo Padilla attacked Crisostomo Amarillo with a bolo, inflicting fatal wounds. Anita Galamgam attempted to flee but was blocked and attacked by Boy Batin, also sustaining fatal wounds. While the victims lay on the ground, Benjamin Padilla took the money from Crisostomo's waist. Francisco Doton, who was cutting grass nearby, witnessed the assault. Mateo Padilla instructed Doton to pick up a bag of money and cover the bloodstains, which Doton did under threat of death. Doton took P9,000.00 from the bag, threw the bag in the river, and deposited the money in his bank account. Procedural History: An information for robbery with double homicide was filed against Mateo Padilla, Benjamin Padilla, Francisco Doton, and Boy Batin. Boy Batin remained at large. Francisco Doton was discharged as a government witness. The trial court found Mateo Padilla and Benjamin Padilla guilty beyond reasonable doubt of robbery with double homicide, sentencing them to reclusion perpetua and ordering them to jointly and severally indemnify the heirs of the deceased. Mateo Padilla did not appeal. The Petition: Benjamin Padilla appealed his conviction, alleging that the trial court erred in convicting him based on the testimony of Francisco Doton, a co-accused discharged as a state witness, and in discrediting his defense and witnesses.
Issue(s)
Whether the trial court gravely erred in convicting the defendant-appellant Benjamin Padilla on the strength of the testimony of Francisco Doton, a co-accused discharged as a state witness. Whether the trial court gravely erred in discrediting the testimony of the defendant-appellant and his witnesses in light of alleged incredibility and gross inconsistencies in the testimonies of the prosecution witness, Francisco Doton. Whether the trial court gravely erred in finding the defendant-appellant guilty beyond reasonable doubt of the crime charged.
Ruling
The judgment of the trial court finding the accused Mateo Padilla and Benjamin Padilla guilty beyond reasonable doubt of robbery with double homicide is affirmed, with the modification that the indemnity for the death of the couple should be raised to P30,000.00 each. Costs are against the appellant.
Ratio Decidendi
On the conviction based on the testimony of a discharged state witness: The Court affirmed the conviction of Benjamin Padilla based on the testimony of Francisco Doton, a co-accused discharged as a state witness. The appellant contended that Doton should not have been discharged as he was not the least guilty. However, the Court found that Doton's participation appeared to be that of a mere accessory, or at most, a participant who was not the most guilty, which satisfies the requirement for discharging a witness under Section 9, Rule 119 of the Rules of Court. The Court found Doton's testimony credible, despite his initial fear for his life which led him to delay revealing the full truth. His identification of Benjamin Padilla was made even before Juan Padilla informed the police about Doton's bank deposit, negating the claim of revenge as a motive. On the alleged incredibility and inconsistencies in Doton's testimony: The Court found that the alleged contradictions in Doton's testimony were on minor matters and did not impair his credibility. Instead, these minor inconsistencies were considered badges of truthfulness and candor, as they indicated that the witness was not reciting a rehearsed story. For instance, his initial statement about seeing three accused following the victims and later saying no one else passed was interpreted as referring to persons other than the accused. His initial claim that the P9,000.00 was part of his wife's savings, later admitted as his share of the loot, was explained by his fear for his life. Similarly, his initial statement of only knowing Mateo Padilla and later identifying Benjamin Padilla after being shown by the station commander was deemed acceptable given the circumstances and his ability to recognize him upon seeing him. On the finding of guilt beyond reasonable doubt and the defense of alibi: The Court found Benjamin Padilla guilty beyond reasonable doubt. The defense of alibi presented by Benjamin Padilla, claiming he was at a barrio fiesta and his son's baptism, could not prevail against the positive identification made by Francisco Doton. The Court noted that even if their alibi allegations were true, it was still possible for them to have gone to the scene of the crime and returned to their residences. The Court reiterated that the sole testimony of a witness, if credible, is sufficient for conviction. Mateo Padilla's failure to mention Benjamin's identity in his sworn statement was attributed to Benjamin being his nephew, suggesting a possible attempt to protect him.
Main Doctrine
The sole testimony of a credible witness, even if a co-accused discharged as a state witness, is sufficient for conviction, provided it meets the required standard of proof beyond reasonable doubt. Minor inconsistencies in the witness's testimony do not necessarily impair credibility and may even serve as badges of truthfulness.