People v. Resayo
REITERATIONFacts
The Antecedents: On February 5, 1989, Roberto C. Aguinaldo was fatally stabbed, and Alfredo A. Braga was seriously wounded. Emmie Resayo y Cruz (Resayo) and Ricardo Reyes y Cruz (Reyes) were charged with homicide and frustrated homicide, respectively, for these acts. The prosecution alleged that at a party, a confrontation arose between Braga's group and the Reyes brothers' group. While Braga's group was heading home, Larry Reyes stabbed Braga. Subsequently, Resayo appeared and stabbed Aguinaldo. Later, Reyes stabbed Braga again. Procedural History: The Regional Trial Court (RTC) of Pasig City found Resayo and Reyes guilty beyond reasonable doubt of homicide and frustrated homicide. The RTC sentenced Resayo to suffer indeterminate penalties for both crimes and ordered them to pay civil indemnity, funeral expenses, and attorney's fees to the heirs of Aguinaldo, and medical expenses and attorney's fees to Braga. The Court of Appeals affirmed the RTC's decision. The Petition: Resayo filed a petition for review with the Supreme Court, questioning the credibility of prosecution witnesses, the finding of conspiracy, the rejection of his alibi, and the disregard of his voluntary surrender to the police.
Issue(s)
Whether the Court of Appeals erred in finding the testimonies of the prosecution witnesses credible despite the judge who penned the decision not hearing their entire testimonies. Whether the Court of Appeals erred in ruling that conspiracy existed between the accused. Whether the Court of Appeals erred in not recognizing the alibis of the accused. Whether the Court of Appeals erred in disregarding Resayo's gesture of accepting the police's invitation as a sign of innocence. Whether the award of actual damages was proper.
Ruling
The Supreme Court partly granted the petition. It found petitioner Emmie Resayo guilty only of homicide and sentenced him to an indeterminate sentence of imprisonment ranging from eight years and one day of prision mayor as minimum to fourteen years, eight months and one day of reclusion temporal as maximum. The Court ordered Resayo to pay the heirs of Roberto Aguinaldo ₱50,000 as civil indemnity, ₱7,500 for funeral expenses, and ₱10,000 for attorney's fees. The Court modified the award for funeral expenses, disallowing unsubstantiated claims.
Ratio Decidendi
On the credibility of the prosecution witnesses: The Court held that a judge who did not hear the entire testimonies of witnesses can still render a valid decision, especially if the full record is available and the judge had the opportunity to observe the demeanor of key witnesses. The Court found no improper motive for the eyewitness, Walter John Victoria, to falsely testify against Resayo, giving his testimony full faith and credit. Inconsistencies in minor details of a witness's statement do not necessarily impair credibility, and the testimony of a single credible witness is sufficient for conviction. On the finding of conspiracy: The Court disagreed with the lower courts' finding of conspiracy. It reasoned that the manner in which Resayo stabbed Aguinaldo and Reyes stabbed Braga did not clearly and convincingly show a common intent. Victoria's testimony indicated Resayo suddenly appeared and stabbed Aguinaldo while the latter was chasing Larry Reyes, suggesting a possible reaction to protect his cousin rather than a pre-conceived plan to retaliate for teasing. The Court emphasized that when faced with equally plausible but variant versions of events, the version favoring the accused's acquittal or least liability should be preferred. Thus, each accused should be held liable only for their individual acts. On the alibi of Resayo: The Court reiterated that alibi is a weak defense, especially when the accused is positively identified by a credible witness. Resayo failed to establish by clear and convincing evidence that it was physically impossible for him to be at the crime scene. His mobility as a tricycle driver, coupled with conflicting statements about his whereabouts, weakened his alibi. The Court found that there was a possibility he could have been present at the crime scene. On Resayo's accession to police's invitation: The Court dismissed Resayo's argument that his voluntary compliance with the police invitation was proof of innocence. It stated that such behavior does not sufficiently rebut eyewitness testimony or serve as conclusive proof of innocence, as it is not extraordinary for individuals to cooperate with police investigations. On the award of actual damages: The Court modified the award for funeral expenses. While ₱7,500 was supported by receipts, the remaining ₱7,500 of the ₱15,000 claimed was unsubstantiated. The Court held that actual damages cannot be based on mere allegations and require competent evidence, such as receipts, for substantiation.
Main Doctrine
The Court found that while the prosecution sufficiently identified the accused as the perpetrator of the stabbing, the evidence did not establish conspiracy among the accused. Therefore, each accused should be held liable only for their individual criminal acts. The Court also modified the award for actual damages due to lack of substantiating receipts.