People v. Viente
REITERATIONFacts
The Antecedents: An information was filed charging Lope Viente y Mapili with violation of Republic Act No. 6539 (Anti-Carnapping Act). The accused, along with two unidentified individuals, allegedly boarded an Isuzu passenger jitney driven by Narciso Cabatas. One of the men poked a gun at Cabatas' nape, ordered the other passengers to alight, and then took control of the vehicle. Cabatas was pushed out, and he heard one of the perpetrators say, "Pareng Lope, patakbuhin mo na ang jeep!" The vehicle was taken against the will of the driver and to the prejudice of the owner, Lucila Crispino. Procedural History: After trial, the Regional Trial Court (RTC) of Manila found the accused guilty beyond reasonable doubt and sentenced him to thirty (30) years imprisonment. The accused appealed the decision. The Petition: The accused-appellant argued that the trial court gravely erred in disregarding his defenses of denial and alibi, and in finding him guilty beyond reasonable doubt.
Issue(s)
Whether the trial court gravely erred in disregarding the defenses of denial and alibi given by the accused-appellant, and in disregarding the credible and corroborative testimonies of the accused's witnesses in support of those defenses. Whether the admissibility of the accused's uncounselled statements should be considered. Whether the trial court gravely erred in finding that the accused-appellant was guilty beyond reasonable doubt of violating Republic Act No. 6539. Whether the penalty imposed by the trial court was correct.
Ruling
The appealed judgment is AFFIRMED in all other respects, except as to the modification regarding the penalty. The appellant is sentenced to suffer an indeterminate penalty of imprisonment ranging from seventeen (17) years and four (4) months as minimum to thirty (30) years as maximum.
Ratio Decidendi
On the credibility of Narciso Cabatas and the defense of alibi, and the sufficiency of alibi witnesses: The Court found no merit in the appellant's attempt to discredit Narciso Cabatas. The relationship of Cabatas with the owners of the jeepney did not disqualify him from testifying nor render his testimony unworthy of belief, as there was no showing of improper motive. The alleged inconsistency between Cabatas' testimony and the Alarm Report was explained by the fact that the report was a brief summary by police officers and not under oath, and Cabatas, with only a Grade 6 education, could not speak or write English. Furthermore, Cabatas' sworn statement corroborated his testimony. The alleged failure to immediately inform Mrs. Crispino about the statement heard was contradicted by their testimonies, and Cabatas' initial reticence to reveal the statement to the police was satisfactorily explained by his fear. The Court reiterated the axiomatic rule that the defense of alibi cannot prevail over the positive identification of an accused. In this case, Cabatas positively identified the appellant, and the interior lights of the jeepney were on, making identification plausible. The appellant's own testimony was silent on his activities during the incident, and his alibi was supported only by witnesses, which is insufficient against positive identification. The Court held that the testimony of three witnesses supporting the appellant's alibi was not sufficient to exonerate him. The Court emphasized that in determining the sufficiency of evidence, the number of witnesses is not as important as the credibility, nature, and quality of their testimony. Witnesses are weighed, not numbered, and the testimony of a single witness can suffice for conviction if trustworthy and reliable. The trial judge is in a better position to assess the credibility of witnesses. On the admissibility of uncounselled statements: The Court noted that while the appellant's statements were obtained without the assistance of counsel, their inadmissibility under the Constitution was not squarely raised. The Court found it unnecessary to dwell on their inadmissibility as the evidence on record was adequate for conviction. The existence of independent evidence apart from the uncounselled confession was sufficient for conviction. On the finding of guilt beyond reasonable doubt: The Court found that the evidence on record, particularly the positive identification by the witness, was sufficient to establish the guilt of the accused beyond reasonable doubt. On the penalty imposed: The Court agreed with the Solicitor General that the trial court erred in imposing a straight penalty of thirty years. The carnapping was committed with violence or intimidation. Under Section 14 of R.A. No. 6539, the penalty is imprisonment for not less than seventeen years and four months and not more than thirty years. Applying Section 1 of the Indeterminate Sentence Law, the proper penalty should be an indeterminate sentence, set at seventeen (17) years and four (4) months as minimum to thirty (30) years as maximum.
Main Doctrine
The defense of alibi cannot prevail over the positive identification of the accused by the victim, especially when the identification is corroborated by other evidence and the alibi is weak or unsubstantiated. The penalty for carnapping committed with violence or intimidation against persons should be an indeterminate sentence.