Abaya v. People
REITERATIONFacts
The Antecedents: Petitioner Reynaldo Abaya, along with Rolando Acedo and Francisco de la Cruz, was charged with robbery with homicide and physical injuries. Rolando Acedo remained at large, and Francisco de la Cruz died during trial. The prosecution's case hinged on the testimony of a lone eyewitness, Alexis Bensorto. Bensorto testified that he was sent to buy softdrinks by the victim, Luis Bartolome. On his way, he was accosted and robbed by Rolando Acedo and Reynaldo Abaya. Subsequently, while Bensorto and Bartolome were in a pick-up truck, Rolando Acedo and Francisco de la Cruz confronted them. During this confrontation, Reynaldo Abaya emerged from a gate, pointing a .45 caliber gun at Luis Bartolome. Francisco de la Cruz ordered Abaya to shoot Bartolome, which Abaya did. After shooting Bartolome, Abaya frisked the victim, taking two wads of P100 bills and a bracelet. Bensorto was then dragged into the pick-up, and de la Cruz told Abaya to shoot Bensorto as well. Bensorto managed to escape and later reported the incident. The defense presented witnesses who claimed Abaya was not the shooter and that the incident was a result of an attack on Abaya and Acedo. Procedural History: The Regional Trial Court (RTC) of Malolos, Bulacan, convicted Reynaldo Abaya of homicide, sentencing him to an indeterminate penalty of six (6) years and one (1) day of prision mayor to twelve (12) years and one (1) day of reclusion temporal, and ordering him to indemnify the heirs of the victim. The Court of Appeals affirmed the RTC's decision, and a motion for reconsideration was denied. The Petition: Petitioner Reynaldo Abaya filed a petition for review, questioning whether the lone testimony of Alexis Bensorto was sufficient to convict him of homicide, particularly given alleged inconsistencies regarding the robbery aspect.
Issue(s)
Whether the lone testimony of Alexis Bensorto is sufficient to convict the petitioner of homicide. Whether the alleged inconsistencies in Bensorto's testimony regarding the robbery negate his credibility as to the shooting.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, upholding the conviction of Reynaldo Abaya for homicide. The Court increased the indemnity for the death of the victim to P50,000.00.
Ratio Decidendi
On the sufficiency of lone eyewitness testimony: The Court reiterated that the testimony of a lone eyewitness, if credible and positive, can be sufficient for conviction. In this case, Alexis Bensorto positively identified Reynaldo Abaya as the person who fired the fatal shot at Luis Bartolome. The conditions of visibility at the time of the incident were deemed adequate, with light coming from a Meralco lamp post and the house of Rolando Acedo. Bensorto's identification of Abaya was made spontaneously and unhesitatingly, despite the chaotic circumstances. The Court found no reason to doubt Bensorto's account of the shooting itself, even if other aspects of his testimony were questioned. On alleged inconsistencies and the principle of falsus in uno, falsus in omnibus: The Court addressed the petitioner's argument that inconsistencies in Bensorto's testimony, particularly regarding the robbery of the victim, rendered his entire testimony incredible. The Court firmly rejected the application of the principle of falsus in uno, falsus in omnibus as an absolute rule. It is well-established jurisprudence that a witness's testimony may be believed in part and disbelieved in part. The Court noted that while Bensorto's testimony about the robbery might not have been fully substantiated, he remained steadfast in his positive identification of Abaya as the triggerman. The Court found that this partial disbelief did not invalidate his core testimony regarding the shooting, especially since the trial court and the Court of Appeals found his identification of the assailant to be credible. The Court cited several previous decisions, including People v. Espinosa, People v. Mozar, People v. Pacada, Jr., and People v. Gohol, to support the principle that a witness can be believed in part and disbelieved in part.
Main Doctrine
The principle of falsus in uno, falsus in omnibus is not an absolute rule; a witness's testimony may be believed in part and disbelieved in part. Positive identification by a credible eyewitness, even if the witness may have erred on other details, is sufficient for conviction.