People v. Villanueva
REITERATIONFacts
The Antecedents: Diosdado Meniano was hacked to death. Rogelio Villanueva and Mamerto Durana were charged with murder. Villanueva remained at large, so only Durana was tried. Durana was sentenced to reclusion perpetua and ordered to indemnify the heirs of the victim. On November 12, 1992, around 10:30 PM, in Barangay Tagpuro, Tacloban City, Diosdado Meniano and his wife Gloria were awakened by a loud voice from outside challenging Diosdado to a fight. Gloria recognized the voice as Mamerto Durana's. After repeated challenges and a threat to go up the house, Diosdado went down armed with a bolo. Gloria, peeping through the bamboo walls, saw Durana clearly and also saw Rogelio Villanueva hiding near San Francisco plants. As Diosdado exited, Villanueva immediately hacked him. Durana continued to taunt Diosdado. Both Villanueva and Durana then fled. Elenita Meniano, a neighbor, corroborated that she heard Durana challenging Diosdado and saw Villanueva hack Diosdado after he went down. She also saw Durana brandishing a bolo near the crime scene after the incident. The medico-legal officer ascribed the cause of death to "shock and hemorrhage due to hacking wounds of the right basal portion of the skull, lacerating the spinal column." Procedural History: The Regional Trial Court (RTC) found Mamerto Durana guilty of murder and sentenced him to reclusion perpetua, ordering him to indemnify the heirs of Diosdado Meniano in the amount of P50,000.00. The Petition: Accused-appellant Durana contended that the trial court erred in (a) failing to consider that he was not a party respondent during the preliminary investigation and (b) giving credence to the testimony of Gloria Meniano.
Issue(s)
Whether the absence of a preliminary investigation involving the accused-appellant renders the information invalid or affects the court's jurisdiction. Whether the trial court erred in giving credence to the testimony of the victim's wife, Gloria Meniano, despite alleged inconsistencies.
Ruling
The Supreme Court affirmed the decision of the RTC, finding accused-appellant Mamerto Durana guilty of murder and imposing the penalty of reclusion perpetua, with an order to indemnify the heirs of Diosdado Meniano in the amount of P50,000.00.
Ratio Decidendi
On the issue of preliminary investigation: The Court held that the absence of a preliminary investigation does not impair the validity of the information or affect the jurisdiction of the court. It is settled that if no preliminary investigation has been held, or if it is flawed, the trial court may, on motion of the accused, order an investigation or reinvestigation and hold the proceedings in abeyance. However, in this case, accused-appellant Durana failed to invoke his right to a preliminary investigation before or at the time he entered his plea at arraignment. Therefore, he could no longer invoke that right at such a late stage of the proceedings. The argument that he was not made a respondent in the preliminary investigation was deemed without merit. On the credibility of Gloria Meniano's testimony: The Court reiterated its policy to sustain the factual findings of the trial court, which is in a better position to assess the evidence and the credibility of witnesses. Discrepancies on minor matters do not impair the essential integrity of the prosecution's evidence. The alleged inconsistencies in Gloria Meniano's testimony regarding whether Durana was asking for a cigarette or challenging Diosdado to a fight, and the timing of the accused's departure, were considered minor and trivial. These alleged inconsistencies were found to strengthen rather than weaken her credibility, as honest witnesses may commit honest lapses on minor details, especially when recalling a startling event involving a loved one. The Court clarified that Gloria's testimony in court, which positively identified Rogelio Villanueva as the one who hacked her husband and Mamerto Durana as the one who challenged Diosdado out of the house, jibed with her sworn statement and clearly pointed to Durana's role in facilitating the attack. The Court found no inconsistency regarding the perpetrator of the hacking, as Gloria consistently identified Villanueva as the one who hacked her husband.
Main Doctrine
Conspiracy can be inferred from the concerted acts of the accused pointing to a joint purpose and design, and the guilt of one is imputable to all. The absence of a preliminary investigation does not impair the validity of the information or the jurisdiction of the court, especially if the accused fails to invoke such right before or at the time of arraignment.