People v. Libungan
REITERATIONFacts
The Antecedents: The accused, Mario Libungan, returned home from work and had a quarrel with his wife, Juanita dela Cruz Libungan, over money. He then put a white shirt over his head. When Juanita returned, Mario tackled her, causing her to fall. While she was trying to get up, he kneeled over her and stabbed her twice with a bladed weapon, once on the left side of the back and once on the upper chest. There were also seven contusions and abrasions on her body. The fatal wound was on the back. Mario then left through the kitchen, damaging a portion of the wall to create the impression of a break-in. Alberto dela Cruz, Juanita's brother, was awakened by cries and, along with his brothers Josefino and Eduardo, went to Juanita's house. They found Juanita being helped by Arsing and she told them that Mario had stabbed her. She died before reaching the hospital. Mario was invited for questioning. Procedural History: The Regional Trial Court, Branch 70, Binangonan, Rizal, convicted the accused of Parricide and sentenced him to reclusion perpetua, P30,000.00 as damages, and costs. The Petition: The accused appealed the decision, invoking the defense of alibi and claiming a thief killed his wife.
Issue(s)
Whether the trial court erred in convicting the accused of parricide. Whether the testimony of the seven-year-old son, Crisanto, is credible. Whether the defense of alibi is tenable.
Ruling
The Supreme Court AFFIRMED the appealed decision, with the modification that the amount of damages be increased from P30,000.00 to P50,000.00.
Ratio Decidendi
On the conviction for Parricide: Based on the credible testimony of the sole eyewitness, Crisanto, and the corroboration from the victim's brothers, the Court found sufficient evidence to establish the guilt of the accused beyond reasonable doubt for the crime of parricide. The accused's act of covering his face with a shirt, his subsequent actions of tackling and stabbing his wife, and his attempt to make it appear as a break-in all point to his culpability. The Court affirmed the trial court's decision, increasing the damages awarded. On the credibility of the child witness: The Court found the testimony of seven-year-old Crisanto Libungan to be clear and convincing, despite minor inconsistencies. These inconsistencies, pertaining to minor details such as whether he and his younger brother saw the stabbing or if he woke up to the quarrel or simply saw it already happening, do not detract from his credibility. The Court noted that such minor contradictions are expected from a child witness and can even strengthen credibility by erasing suspicion of a rehearsed testimony. Crisanto positively identified his father as the perpetrator of the crime, and his testimony was corroborated by the victim's brothers, who testified that Juanita identified Mario as her assailant before she died. The Court also deferred to the trial judge's assessment of the child's competency to testify, as the judge had the opportunity to observe the witness's demeanor and intelligence. On the defense of alibi: The Court ruled that the defense of alibi must necessarily fall because the accused was positively identified by prosecution witnesses as the assailant. Furthermore, the Court found that the twin requisites of alibi – absence from the scene of the crime and physical impossibility to be at the scene – were not met. The distance between the accused's house and his workplace was only three kilometers, traversable in ten to fifteen minutes, making it physically possible for him to have been at the scene of the crime.
Main Doctrine
The testimony of a child witness, despite minor inconsistencies on collateral matters, can be credible if it is clear and convincing on the essential facts of the crime, and such testimony is corroborated by other evidence. Alibi is unavailing when the accused has been positively identified by prosecution witnesses.