People v. De Labajan
REITERATIONFacts
The Antecedents: On September 10, 1994, at around 8:00 PM in Barangay Luksuhin, Silang, Cavite, Romeo Miano, Jr. and Marites Carpio were inside the house of Evelyn Termo. At around 11:00 PM, gunshots were heard from outside. One bullet hit Marites Carpio on the left forearm and chest, while another hit Romeo Miano, Jr. in the chest, causing his instantaneous death. Procedural History: Two separate informations were filed against Armando De Labajan @ Gadoy for murder (Criminal Case No. TG-2426-95) and frustrated murder (Criminal Case No. TG-2425-95). The accused pleaded not guilty to both charges. The cases were tried jointly. The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt of murder and frustrated murder. The RTC imposed an indeterminate penalty for frustrated murder and reclusion perpetua for murder, along with civil indemnity. An amended decision modified the penalty for frustrated murder. The accused appealed. The Petition: The accused-appellant raised errors concerning the trial court's reliance on prosecution witnesses' testimonies despite alleged inconsistencies and disregarding defense evidence, and the insufficiency of proof to establish guilt beyond reasonable doubt.
Issue(s)
Whether the trial court erred in giving full weight and credence to the testimony of prosecution witnesses and disregarding defense evidence. Whether the trial court gravely erred in convicting the accused-appellant despite insufficiency of proof to establish guilt beyond reasonable doubt, considering the alleged inconsistencies in the prosecution witness's testimony.
Ruling
The Supreme Court affirmed in toto the appealed decision and the amended decision of the trial court, finding the accused-appellant Armando De Labajan @ Gadoy guilty beyond reasonable doubt of murder and frustrated murder. The award of moral damages was deleted and considered as civil indemnity ex delicto.
Ratio Decidendi
On the credibility of prosecution witnesses and sufficiency of proof: The Court reiterated the doctrine that the testimony of a single witness positively identifying the accused, when clear and straightforward, is sufficient to sustain a conviction. The Court found the testimony of Evelyn Termo credible, noting that she had no apparent motive to falsely accuse the appellant and that her testimony was given in a clear and convincing manner. Discrepancies in minor details were deemed to bolster veracity rather than indicate prevarication. The Court also emphasized that the assessment of witness credibility is best left to the trial court, which had the unique opportunity to observe the witnesses firsthand. The Court found the defense of alibi unconvailing, especially given the proximity of the accused to the crime scene and the inconsistencies in his own testimony and that of his corroborating witness, Cosme Sierra. The Court noted that the accused's explanation for not attending to his injured brother was also questionable. Therefore, the evidence presented by the prosecution was deemed sufficient to prove the guilt of the accused beyond reasonable doubt. On the alleged inconsistencies in Evelyn Termo's testimony and sufficiency of proof: The Court acknowledged a potential inconsistency in Evelyn Termo's testimony regarding the exact moment she saw the accused fire the gun. However, citing established jurisprudence, the Court held that discrepancies in minor details do not necessarily impair the credibility of a witness and can even serve to bolster the probative value of their testimony. The alleged inconsistency did not refute the positive identification made by witness Termo that it was the accused who fired the shots. The Court also noted that the accused's claim that Evelyn Termo had a motive to lie due to her nephew being accused of stabbing the accused's brother was not substantiated.
Main Doctrine
The testimony of a single witness positively identifying the accused as the perpetrator of the crime, when clear and straightforward, is sufficient to sustain a conviction. Alibi cannot prevail over positive testimonies of prosecution witnesses.