People v. Siccuan
REITERATIONFacts
The Antecedents: On September 4, 1982, Benjamin de la Cruz was shot and killed during a program capping a seminar he headed in Iguig, Cagayan. Fidel Udarbe and Dante Claravall witnessed the incident and positively identified petitioner Constante Siccuan as the assailant. Dr. Edmundo Borja conducted a postmortem examination, finding four gunshot wounds on the victim, with the cause of death being shock due to internal hemorrhage. Procedural History: The Provincial Fiscal of Cagayan charged Constante Siccuan with murder. Petitioner pleaded not guilty. After the prosecution rested its case, the defense filed a demurrer to evidence, which was denied. Petitioner denied the charge, claiming an NPA member was responsible and that he was outside the building when the shots were fired. The Regional Trial Court (RTC) found petitioner guilty of homicide and imposed a penalty of eight (8) years of prision mayor to seventeen (17) years and four (4) months of reclusion temporal, and ordered him to indemnify the heirs. The Court of Appeals (CA) affirmed the RTC decision in toto, and a subsequent motion for reconsideration was denied. The Petition: Petitioner filed a petition for review on certiorari, assailing the CA's affirmation of the lower court's denial of his demurrer to evidence, its giving credence to prosecution witnesses despite alleged contradictions, and its ruling convicting him of homicide.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in affirming the denial of the petitioner's demurrer to evidence, and whether the Court of Appeals erred in giving credence to the testimonies of the prosecution witnesses despite alleged material contradictions and inconsistencies. Whether the Court of Appeals erred in affirming the conviction of the petitioner for homicide based on the evidence presented.
Ruling
The Supreme Court denied the petition for review on certiorari and affirmed the Decision and Resolution of the Court of Appeals. The Court held that the assigned errors pertain to questions of fact, specifically the credibility of witnesses, which are not proper for a petition for review on certiorari under Rule 45. The Court reiterated that it is not a trier of facts and will not disturb the findings of the CA affirming those of the RTC, absent any showing of misapprehension of facts or lack of evidentiary support.
Ratio Decidendi
On the denial of the demurrer to evidence and the credibility of witnesses: The Court emphasized that its jurisdiction in a petition for review on certiorari under Rule 45 is limited to errors of law, not of fact. Petitioner's arguments regarding the discrepancy in the number of gunshot wounds and the initial failure of eyewitnesses to name him as the culprit, as well as the lack of ballistics and paraffin tests, all pertain to factual matters and the credibility of witnesses. The Court reiterated its consistent adherence to the rule that findings of fact of the Court of Appeals, affirming those of the trial court, are accorded the highest respect and finality, especially when the issue hinges on witness credibility. The Court noted that it is not the proper venue to calibrate evidence anew or make new factual determinations. Petitioner failed to show any cogent reason to reverse the findings of both lower courts. The Court cited Reyes, Jr. vs. Court of Appeals to underscore that inconsistencies in testimony do not affect veracity if they do not pertain to material points, and that the trial court had the better opportunity to observe the witnesses' demeanor. The Court found that the prosecution witnesses positively identified the petitioner, and any perceived inaccuracies were attributed to the sudden and startling nature of the event. Therefore, the lower courts did not err in concluding that the petitioner was the one who shot the victim based on the eyewitness testimonies. On the conviction for homicide: The Court found no reversible error in the affirmation of the conviction for homicide. The core of the petitioner's argument rested on the alleged insufficiency of evidence and the credibility of prosecution witnesses, which are factual issues. As established, the Supreme Court does not re-examine factual findings in a Rule 45 petition. The positive identification by eyewitnesses, despite minor alleged inconsistencies, was given credence by the lower courts. The Court reiterated that it is not its function to examine the weight of evidence supporting the assailed decision. The petitioner's arguments did not fall under any of the exceptions to the rule that factual issues are not reviewable by the Supreme Court in a petition for certiorari. Thus, the conviction was upheld based on the evidence presented and appreciated by the RTC and CA.
Main Doctrine
The Supreme Court, in an appeal by certiorari under Rule 45, is limited to reviewing errors of law and not of fact, and will not ordinarily disturb the findings of fact of the Court of Appeals affirming those of the trial court, especially when the issue hinges on the credibility of witnesses, unless there is a misapprehension of facts or the findings are devoid of support from the evidence.