Fernando Manangan v. Court of Appeals
REITERATIONFacts
The Antecedents: The underlying dispute concerns the fatal stabbing of Carlos Estacio. The prosecution alleged that on July 15, 1987, in Baguio City, Fernando Manangan, with intent to kill, willfully, unlawfully, and feloniously attacked and stabbed Carlos Estacio, inflicting injuries that caused his death due to hypovolemic shock secondary to massive intrathoracic hemorrhage. The petitioner, Fernando Manangan, denied the charge, claiming that Freddie Lacsamana was the assailant and that he merely intervened to disarm Lacsamana. Procedural History: The petitioner, Fernando Manangan, was charged with homicide via an Information filed in the Regional Trial Court (RTC) of Baguio City, Branch 7. After a trial, the RTC rendered a judgment on March 10, 1997, convicting the petitioner of homicide and sentencing him to imprisonment and to pay civil indemnity. The petitioner appealed this decision to the Court of Appeals (CA), arguing that the RTC erred in giving undue credence to the prosecution witnesses and in not acquitting him due to reasonable doubt. The CA affirmed the RTC's decision. The Petition: The petitioner seeks a review of the Court of Appeals' decision through a petition for review. He reiterates the same issues raised before the CA, contending that both the trial court and the appellate court erred in giving full probative weight to the testimonies of prosecution witnesses Johnny It-itan and Angelina Tobias, despite alleged inconsistencies, and in finding the petitioner's and his witness's testimonies incredible. The petitioner argues that the courts should have acquitted him based on reasonable doubt.
Issue(s)
Whether the trial court and the Court of Appeals erred in giving credence to the testimonies of prosecution witnesses Johnny It-itan and Angelina Tobias. Whether the petitioner should be acquitted on the ground of reasonable doubt.
Ruling
The petition is DENIED. The decisions of the RTC and the Court of Appeals are AFFIRMED.
Ratio Decidendi
On the credibility of prosecution witnesses: The Court held that the findings of fact of the trial court, including its assessment of the credibility of witnesses, are accorded high respect by appellate courts. The petitioner failed to show that the trial court ignored, misconstrued, or misinterpreted facts and circumstances of substance. The Court found that the petitioner selectively quoted portions of It-itan's testimony to support his claim, omitting unfavorable parts. Furthermore, the Court found no merit in the petitioner's assertion that Angelina Tobias was not present at the crime scene, noting that her testimony was corroborated by It-itan and that the petitioner's counsel did not cross-examine Tobias on her presence. The Court also clarified that It-itan's failure to mention Tobias by name or the full name of another companion did not invalidate Tobias's testimony, as there was no evidence to disprove her presence. On reasonable doubt: The Court found no reasonable doubt to warrant the petitioner's acquittal. The testimonies of the prosecution witnesses, which were found credible by the lower courts, established the petitioner's culpability. The petitioner's defense, which relied on his denial and the testimony of his witness, was disbelieved by the trial court. The Court reiterated the principle that the credibility of witnesses is a matter best determined by the trial court, which had the opportunity to observe their demeanor and manner of testifying. The petitioner's claim that he merely wrestled the knife from Lacsamana and passed it to another person was not given credence. The Court also deemed the petitioner's settlement of a frustrated homicide case irrelevant to the present homicide charge.
Main Doctrine
The findings of fact of the trial court, as well as its calibration of the evidence and assessment of the credibility of witnesses, are accorded high respect by appellate courts, and will not be disturbed unless there is a showing that the trial court ignored, misconstrued, or misinterpreted facts and circumstances of substance that, if considered, would alter the outcome of the case.