People v. Daraman
REITERATIONFacts
The Antecedents: On December 28, 1992, an Information for robbery with homicide was filed against Edgardo Lumenarias, Robert Daraman, Elias Fuentes, and Jessie Oblima. The Information alleged that on the evening of September 30, 1992, the accused, conspiring and confederating, armed with handguns, robbed spouses Fausto and Lina Labrador of cash and wrist watches totaling P4,000.00. On the occasion of the robbery, Edgardo Lumenarias shot Lina Labrador, causing her death. Procedural History: Edgardo Lumenarias pleaded guilty and was meted an indeterminate sentence. Robert Daraman pleaded not guilty. After trial, the Regional Trial Court of Panabo, Davao, in a Decision dated January 25, 1996, found Robert Daraman guilty beyond reasonable doubt as co-principal in the crime of Robbery with Homicide, sentencing him to suffer the penalty of reclusion perpetua and to pay civil indemnities. The Petition: Robert Daraman appealed the decision of the trial court, assigning errors in the finding of guilt despite alleged insufficiency of evidence and in giving credence to the testimonies of Fausto Labrador and Bienvenido Piamonte.
Issue(s)
Whether the trial court gravely erred in finding accused-appellant Robert Daraman guilty beyond reasonable doubt of robbery with homicide despite the insufficiency of the prosecution's evidence. Whether the trial court gravely erred in giving credence to the testimonies of Fausto Labrador and Bienvenido Piamonte identifying the accused-appellant Robert Daraman as the perpetrator of the crime.
Ruling
The appeal is devoid of merit. The assailed Decision is AFFIRMED.
Ratio Decidendi
On the issue of the trial court gravely erring in finding accused-appellant Robert Daraman guilty beyond reasonable doubt of robbery with homicide despite the insufficiency of the prosecution's evidence: The Court found the prosecution's evidence sufficient for conviction. The positive identification of the appellant by Fausto Labrador, a victim and the widower, was direct, unequivocal, and credible. Labrador testified that he saw the appellant clearly under a bright fluorescent lamp and that the appellant guarded him with a gun pointed at him. The Court reiterated the principle that an affirmative testimony from a credible witness is stronger than a negative testimony. The defense of alibi and denial presented by the appellant could not overcome the positive identification. The testimonies of defense witnesses Edgardo Lumenarias and Alberto Caangay were found to be without value due to inconsistencies and lack of credibility, particularly Lumenarias's retraction of his earlier plea and Caangay's fabricated testimony. The Court emphasized that the accused must be convicted on the strength of the prosecution's evidence, which in this case was found to be sufficient. On the issue of the trial court gravely erring in giving credence to the testimonies of Fausto Labrador and Bienvenido Piamonte identifying the accused-appellant Robert Daraman as the perpetrator of the crime: The Court upheld the credibility of Fausto Labrador's testimony. Despite the trial judge not having personally observed all witnesses due to taking over the case mid-trial, the Supreme Court meticulously reviewed the records and found no reason to differ from the trial court's conclusions. Labrador's identification was direct, unequivocal, and credible, as he saw the appellant's face under a bright light and the appellant guarded him with a gun. The Court debunked the argument that identification is impossible between strangers, citing People v. Bracamonte. Labrador's testimony was corroborated by Bienvenido Piamonte, who was an admitted participant and testified on material points, such as Daraman's presence and role during the robbery. Although Piamonte's testimony came from a "polluted source" as he was granted immunity, the Court held that this fact alone does not make it inadmissible, but requires careful scrutiny, which was done. The corroboration provided by Piamonte strengthened Labrador's testimony and lent credibility to Piamonte's own account. The Court reiterated the doctrine that the testimony of a single credible witness is sufficient for conviction if otherwise trustworthy and reliable, and that there is no law requiring corroboration except when expressly mandated.
Main Doctrine
The testimony of a single credible and trustworthy witness is sufficient to convict an appellant, especially if the witness is not shown to have any bias or ill motive. The defense of alibi and denial cannot prevail over positive identification by a credible witness.