People v. De Castro
REITERATIONFacts
The Antecedents: On July 19, 1987, during a barangay benefit dance in Marihatag, Surigao del Sur, Macario Aporbo and his companions left the event around 2:30 a.m. on July 20, 1987. As they were walking home, accused-appellant Casimiro de Castro suddenly appeared and attempted to stab Macario Aporbo with a bolo. Antonieto Plaza, appellant's companion, pushed Macario, causing him to fall. Appellant then stabbed Macario in the left chest cavity, resulting in his instantaneous death. The accused fled the scene. Felipe Lopez testified that he saw appellant with a bloodied shirt and bolo and that appellant admitted to stabbing the victim. Procedural History: An information for murder was filed against Casimiro de Castro and Antonieto Plaza. Both accused went into hiding. Antonieto Plaza was captured but escaped, and remains at large. Casimiro de Castro was apprehended later, pleaded not guilty, and was convicted of murder by the Regional Trial Court (RTC), which sentenced him to reclusion perpetua and ordered him to pay damages. The Petition: The accused-appellant appealed his conviction, arguing that the trial court erred in giving full credence to the prosecution witnesses' testimonies due to alleged inconsistencies, in finding him guilty beyond reasonable doubt, and in finding that treachery attended the killing.
Issue(s)
Whether the alleged inconsistencies in the testimonies of prosecution witnesses Yolanda Aporbo and Sergio Sanchez, Jr. regarding the number of companions and the sequence of events before the stabbing render their testimonies unreliable. Whether the trial court erred in finding the accused-appellant guilty beyond reasonable doubt of murder. Whether treachery was present in the commission of the crime.
Ruling
The Supreme Court affirmed the judgment of the Regional Trial Court, finding the accused-appellant guilty beyond reasonable doubt of murder. The Court modified the civil liability by increasing the death indemnity to P50,000.00 and deleting the award for exemplary damages.
Ratio Decidendi
On the alleged inconsistencies in witness testimonies: The Court held that minor inconsistencies in the testimonies of prosecution witnesses regarding collateral details, such as the exact number of companions present, do not necessarily impair their credibility. The Court explained that variations in perspective based on location and peripheral vision are natural. The crucial fact that both eyewitnesses, Yolanda Aporbo and Sergio Sanchez, Jr., consistently identified appellant Casimiro de Castro as the one who stabbed the victim with a bolo in the left chest cavity remained undisturbed. The Court reiterated that inconsistencies on minor details can even bolster the credibility of witnesses, as they suggest that the testimonies were not fabricated. The Court emphasized that the trial court, which had the opportunity to observe the witnesses directly, is in the best position to assess their credibility. On the guilt of the accused-appellant: The Court found no merit in the second assigned error, stating that there were two eyewitnesses who positively identified the appellant as the perpetrator. The Court gave greater credence to the positive identification by eyewitnesses over the self-serving testimony of the accused-appellant. The defense of alibi presented by the appellant was found to be flawed and unbelievable. The corroborating witness, Cresencio Campos, testified that he continuously saw the appellant sleeping from 11:00 P.M. to 5:00 A.M. while Campos and another person were drinking tuba in the living room, which the Court found inherently improbable. Furthermore, the distance between the house of the alibi witness and the scene of the crime was only 25 meters, making it possible for the appellant to have left unnoticed. The Court concluded that the alibi was easily contrived and rejected it. On the presence of treachery: The Court found the third assigned error to be puerile, reiterating the elementary principle that treachery exists when the attack is sudden, unexpected, and without provocation from the victim. The Court found that the appellant attacked the victim surreptitiously and without warning, while the victim was unarmed and unaware of any danger. Although the victim was able to parry the first thrust, this was considered an instinctive reaction rather than a prepared response. Therefore, the mode of attack was treacherous, qualifying the crime to murder.
Main Doctrine
Minor inconsistencies in the testimonies of prosecution witnesses regarding collateral details do not necessarily impair their credibility, especially when they are consistent on the material facts of the crime, such as the positive identification of the perpetrator. The defense of alibi, particularly when corroborated by a witness whose testimony is inherently unbelievable, is disfavored.