Lagunsad v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Emiliano Lagunsad and Julius Cordero were charged with frustrated murder for allegedly stabbing Fidel Wasawas, Jr. on December 8, 1985. The victim and his companion, Edilberto Baqueros, were on their way home from a town fiesta. Wasawas, Jr. agreed to give Cordero and Lagunsad a ride on his motorcycle. Due to Wasawas, Jr. being tipsy, he drove recklessly, causing the motorcycle to crash. Angered by the reckless driving, Lagunsad and Cordero allegedly attacked Wasawas, Jr. with bladed weapons, inflicting multiple wounds. The victim was found by passengers of a passing jeepney and was brought to the hospital, where timely medical intervention saved his life. Lagunsad's defense was that it was Cordero, not him, who inflicted the wounds. Procedural History: The Regional Trial Court (RTC) found petitioner guilty of frustrated homicide, not frustrated murder, as the qualifying circumstances of treachery and evident premeditation were not proven. The RTC considered superior strength as an aggravating circumstance. The Court of Appeals affirmed the RTC's decision. The Petition: Petitioner sought review of the Court of Appeals' decision, arguing that the victim's testimony was insufficient for conviction due to alleged falsity in one part, invoking the maxim falsus in uno, falsus in omnibus. He also questioned the credibility of an eyewitness due to relationship with the co-accused.
Issue(s)
Whether the victim's testimony, despite an allegedly false narration regarding the timing of the stabbing, is sufficient to sustain a conviction, and whether the maxim falsus in uno, falsus in omnibus should be applied to render the victim's entire testimony incredible. Whether the petitioner is guilty of frustrated homicide.
Ruling
The petition is dismissed for lack of merit. The Court of Appeals' decision affirming the petitioner's conviction for frustrated homicide is upheld.
Ratio Decidendi
On the sufficiency of the victim's testimony and the application of falsus in uno, falsus in omnibus: The Court held that the maxim falsus in uno, falsus in omnibus is not a rigid rule of law and is rarely applied. It is within the trial court's discretion to accept credible portions of a witness's testimony and reject those found to be false, especially when corroborated. The Court found no proof that the victim deliberately falsified his account of the first stab wound or was motivated by improper motives. Even if a portion of the testimony were false, the remaining parts, such as the petitioner's act of stabbing the victim, were corroborated by eyewitness Edilberto Baqueros. The crucial fact was not when the victim was stabbed, but who inflicted the wounds, and the petitioner was positively identified as one of the assailants. The Court emphasized that the victim's testimony was corroborated by Baqueros, who witnessed the events after the motorcycle crash. The trial court's rejection of the victim's claim of being stabbed while driving was reasonable, as it contradicted the accused's alleged concern for their safety due to reckless driving. The Court reiterated that the maxim requires willful falsification on material points and does not automatically render the entire testimony incredible if portions are found to be credible based on corroborative evidence and probabilities. On the petitioner's guilt for frustrated homicide: The Court affirmed the findings of the lower courts that the petitioner was guilty of frustrated homicide. While the information charged frustrated murder, the RTC correctly found that the qualifying circumstances of treachery and evident premeditation were not sufficiently proven. The victim sustained multiple wounds that, but for timely medical intervention, could have resulted in death, thus establishing the commission of the crime of frustrated homicide. The RTC's finding of the aggravating circumstance of superior strength was not challenged by the petitioner in his arguments before the Supreme Court. The flight of co-accused Julius Cordero was considered an indication of guilt, but it did not absolve the petitioner, as he was positively identified as having participated in the stabbing. The relationship of eyewitness Baqueros to the co-accused did not automatically disqualify him as biased; his testimony was admissible and considered by the court.
Main Doctrine
The maxim falsus in uno, falsus in omnibus is not a positive rule of law and is rarely applied; a court may accept portions of a witness's testimony while rejecting others, provided there is corroborative evidence or inherent probability. The flight of a co-accused does not absolve another from liability.