People v. Pelen
REITERATIONFacts
The Antecedents: On December 12, 1993, at around 7:00 PM, Maximo Perlada and his wife Narcisa were riding a carabao home when six men blocked their path. A flashlight was shone on Maximo, and a shot was fired, hitting him in the head. Narcisa identified the shooter as Gerlito Pelen, her neighbor. Maximo fell, was shot again by an unidentified companion, and then stabbed to death by other unidentified men. Gerlito Pelen allegedly pulled Narcisa away while the stabbing occurred. Narcisa reported the incident to the barangay captain and the Army detachment but did not immediately name Pelen due to preoccupation with burial arrangements. She later gave a sworn statement on December 14, 1993, implicating Pelen and Cesar Rey, citing prior threats from Rey, often accompanied by Pelen, to evict them from their land. Procedural History: An information for murder was filed against Gerlito Pelen and Cesar Rey. Both pleaded not guilty. The Regional Trial Court of Gumaca, Quezon, Branch 62, convicted Gerlito Pelen of murder, sentencing him to reclusion perpetua, and ordered him to indemnify the heirs. Cesar Rey was acquitted for insufficiency of evidence. The trial court considered nighttime as a generic aggravating circumstance. The Petition: Accused-appellant Gerlito Pelen appealed, arguing that Narcisa's testimony as the sole eyewitness was unreliable due to her initial failure to immediately identify him and that his implication was police-influenced. He also presented an alibi, corroborated by a quack doctor, stating he was home attending to his sick son.
Issue(s)
Whether the lone testimony of the eyewitness, Narcisa Perlada, is sufficient to sustain the conviction of the accused-appellant. Whether the delay in Narcisa Perlada's identification of the accused-appellant renders her testimony incredible. Whether the alibi of the accused-appellant is credible and sufficient to acquit him.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding Gerlito Pelen guilty beyond reasonable doubt of the crime of murder and sentencing him to suffer the penalty of reclusion perpetua. The Court upheld the trial court's assessment of Narcisa Perlada's credibility and found her testimony sufficient for conviction. Cesar Rey's acquittal was also maintained.
Ratio Decidendi
On the sufficiency of the lone eyewitness testimony: The Court held that the testimony of a single witness, if credible and trustworthy, is sufficient for conviction. It emphasized that witnesses are weighed, not numbered, and there is no law requiring corroboration for eyewitness testimony unless expressly mandated. Given the circumstances of the crime, Narcisa was the only possible eyewitness, and her identification of the accused-appellant was found to be convincing and possessed the badge of truthfulness. The Court reiterated the principle that the trial court's assessment of witness credibility, having had the opportunity to observe their demeanor, is accorded the highest respect. On the delay in identification: The Court found Narcisa's delay in immediately identifying the accused-appellant to be justifiable and not indicative of incredibility. She was traumatized by the violent death of her husband and preoccupied with burial arrangements. Her sworn statement implicating the accused-appellant was given only two days after the incident. The Court cited jurisprudence holding that delay in reporting does not, by itself, render testimony unworthy of belief, especially when the witness is related to the victim and the delay is satisfactorily explained. Narcisa's explanation for the delay was deemed reasonable. On the credibility of the alibi: The Court rejected the accused-appellant's alibi. It held that a positive identification by a credible eyewitness destroys the defense of alibi and renders it impotent. For alibi to be given serious consideration, it must be so convincing as to preclude any doubt about the accused's inability to be present at the crime scene. The accused-appellant's alibi was found unconvincing, especially in light of Narcisa's positive identification of him as the perpetrator who shot her husband. The Court noted that the accused-appellant was a neighbor and lived in the same barangay where the crime occurred, making his physical presence plausible.
Main Doctrine
The positive identification of the accused by a credible eyewitness is sufficient to overcome the defense of alibi. Delay in reporting the crime does not necessarily impair the credibility of the witness, especially when satisfactorily explained.