People v. Sison
REITERATIONFacts
The Antecedents: On July 20, 1987, in barangay Dinalaoan, Calasiao, Pangasinan, Daniel Sison y Alegria was charged with Homicide with the Use of Unlicensed Firearm for allegedly shooting John Ventura with an unlicensed firearm, causing his death. The prosecution presented evidence that the appellant arrived on a bicycle, approached John Ventura, drew a gun, uttered "Agka mibabali pare" (Don't interfere, pare!), and shot Ventura when the latter ran towards his house. The victim's sister, Corazon Ventura Crisostomo, intervened and wrested the gun from the appellant. The gun was later surrendered to the police. The medico-legal examination revealed a gunshot wound that caused cardiac failure. A certification confirmed the appellant was not a licensed firearm holder, and the firearm was homemade and unlicensed. Procedural History: The Regional Trial Court of Dagupan City found the accused guilty of Homicide with the Use of Unlicensed Firearm and sentenced him to reclusion perpetua, to indemnify the heirs of the victim P30,000.00, and to pay costs. The accused appealed the decision. The Petition: The accused-appellant insisted on his innocence, assailing the trial court's reliance on the testimonies of prosecution witnesses, whom he deemed biased and incredible, and arguing that his version, corroborated by disinterested witnesses, should have been believed.
Issue(s)
Whether the trial court erred in giving credence to the testimonies of the prosecution witnesses despite their alleged relationship with the deceased and inconsistencies. Whether the appellant's version of the incident, involving a struggle for the gun, is more credible.
Ruling
The Supreme Court affirmed the judgment of the trial court with a modification increasing the indemnity to P50,000.00. The Court found no merit in the appeal, upholding the trial court's findings on the credibility of the prosecution witnesses.
Ratio Decidendi
On the credibility of prosecution witnesses and alleged inconsistencies: The Court held that the trial court's findings on the credibility of witnesses are generally given great weight and will not be disturbed on appeal, absent any showing of grave abuse of discretion. The Court found no reason to disturb the trial court's assessment of the prosecution witnesses' testimonies, stating that the record was bereft of circumstances suggesting their testimonies were mere concoctions. The Court emphasized that the mere fact that witnesses are related to the deceased does not automatically render their testimonies biased or incredible, especially when they have no improper motive to testify falsely. The Court also addressed the alleged inconsistency regarding the exact location and timing of witnesses' observations after the gunshot, classifying it as a minor detail that does not affect the integrity of their testimonies. Such inconsistencies on collateral matters do not touch upon the commission of the crime itself. The Court reiterated that the testimonies of Avelino Alegria and Corazon Ventura-Crisostomo provided positive identification of the appellant as the perpetrator and owner of the gun used. The testimony of Daniel Alegria further corroborated the events. The Court concluded that there were sufficient facts supporting the witnesses' positive identification of the appellant. On the appellant's version of the incident: The Court found no merit in the appellant's claim that he grappled for the gun with the victim, leading to its accidental discharge. The Court gave credence to the prosecution's evidence, which established that the appellant intentionally shot the victim. The appellant's denial and his version of events were found unconvincing in light of the positive testimonies of the prosecution witnesses. The Court noted that the appellant failed to demonstrate any exceptional circumstance that would warrant overturning the trial court's factual findings, which were based on the assessment of witness credibility.
Main Doctrine
Inconsistencies on minor details in the testimonies of witnesses do not affect their credibility, especially when the core facts of the commission of the crime are consistent and corroborated. The appellate court will not disturb the findings of fact of the trial court on the credibility of witnesses absent any showing of grave abuse of discretion.