People v. Cajambab
REITERATIONFacts
The Antecedents: On December 3, 1990, Rodrigo Rogero y Lacandaso was stabbed to death while sitting on a bench at Quintana St., Sta. Mesa, Manila. Accused-appellants Roberto Cajambab y de Rutas and Arnulfo Bandal y Puaso were charged with murder, with the information alleging conspiracy, treachery, and evident premeditation. Procedural History: The Regional Trial Court of Manila, Branch 5, convicted both accused-appellants of murder and sentenced them to reclusion perpetua, with accessory penalties, and ordered them to pay P50,000.00 to the heirs of the victim. The Petition: Accused-appellants appealed the decision, assigning errors to the trial court's appreciation of the prosecution's testimonies as credible and reliable, its failure to give credence to the defense witnesses, and its finding of guilt beyond reasonable doubt.
Issue(s)
Whether the trial court gravely erred in giving full credence to the testimonies of the prosecution witnesses which are highly incredible, inconsistent and unreliable. Whether the trial court gravely erred in not giving full credence to the testimonies of the defense witnesses. Whether the trial court gravely erred in convicting the accused-appellants despite the prosecution's failure to prove their guilt beyond reasonable doubt.
Ruling
The Supreme Court affirmed the conviction for murder but modified the sentence. The accused-appellants were sentenced to suffer imprisonment of ten (10) years and one (1) day of prision mayor maximum to seventeen (17) years, four (4) months and one (1) day of reclusion temporal maximum. They were also ordered to pay P50,000.00 to the heirs of the victim and costs of suit.
Ratio Decidendi
On the credibility of prosecution witnesses and the alleged incredibility, inconsistency, and unreliability of their testimonies: The Court reiterated the rule that findings of the trial court on the credibility of witnesses are given great weight and the highest degree of respect by appellate courts. A careful perusal of the testimonies of the eyewitness Danilo Bitonio and defense witness Estrella Opina revealed no compelling reason to disturb the trial court's findings. The Court noted inconsistencies in Opina's testimony, particularly regarding Bitonio's position during the incident and her own ability to observe. Opina admitted the store was at her back and she looked behind only after the commotion started, contradicting her initial claim that Bitonio was playing cards with her. The Court found Opina's testimony shaky and tentative compared to Bitonio's categorical account of the stabbing. Minor inconsistencies in Bitonio's testimony were considered to lend credence to its spontaneity rather than indicating it was rehearsed. Therefore, the trial court did not err in appreciating Bitonio's testimony. On the alleged failure to give credence to defense witnesses: The Court found the testimony of defense witness Estrella Opina to be shaky and contradictory. Her admission that she looked behind only after the commotion started and that Bitonio was standing behind her raised doubts about her ability to accurately observe the events. The defense's argument that Bitonio could not have seen the stabbing because he was playing cards was not supported by Opina's own testimony, which indicated Bitonio was behind her and she could not ascertain if he saw the stabbing. The Court found no error in the trial court's decision not to give full credence to Opina's testimony. On the alleged failure to prove guilt beyond reasonable doubt: The Court found that the eyewitness testimony of Danilo Bitonio adequately established that the accused-appellants were at the scene and were the ones who stabbed and killed Rodrigo Rogero. Bitonio's detailed account of how Bandal pulled Rogero's head up and stabbed him, followed by Cajambab also stabbing Rogero, and their subsequent chase and further stabbing, was found to be credible. The Court noted that while there were minor inconsistencies, these did not detract from the overall credibility of the testimony. The defense's alibi and counter-narrative were found to be less credible due to the inconsistencies and contradictions in the defense witnesses' testimonies. Thus, the prosecution successfully proved the guilt of the accused-appellants beyond reasonable doubt.
Main Doctrine
The credibility of eyewitness testimony, when found by the trial court to be credible, is given great weight by appellate courts. Minor inconsistencies in testimony may even lend credence to its spontaneity. The presence of mitigating circumstances, such as voluntary surrender, must be appreciated to impose the penalty in its minimum period.