Lascano v. People
REITERATIONFacts
The Antecedents: Petitioner Ruben Lascano was charged with murder along with several co-accused for the killing of Arnold Fernandez. Petitioner absconded but later surrendered and underwent a separate trial. The charge against him was later downgraded to homicide. Eyewitnesses Ofelia Ibacuado and Estrellita Mallari testified that petitioner arrived, uttered threatening words, kicked the victim, and then shot him. The victim died from the gunshot wound. Petitioner presented the defense of alibi, claiming he was traveling to Nueva Vizcaya at the time of the incident and presented bus tickets as proof. Procedural History: The Regional Trial Court (RTC) found petitioner guilty of homicide and sentenced him to an indeterminate penalty. The Court of Appeals affirmed the RTC decision but modified the prison sentence. Both courts rejected petitioner's defense of alibi. The Petition: Petitioner sought review of the Court of Appeals' decision, arguing that the testimonies of the prosecution witnesses were conflicting and that his defense of alibi should have been sustained.
Issue(s)
Whether the Court of Appeals erred in relying on the alleged conflicting testimonies of prosecution witnesses Ofelia Ibacuado and Estrellita Mallari. Whether the Court of Appeals erred in not sustaining petitioner's defense of alibi.
Ruling
The petition is denied. The decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the alleged conflicting testimonies: The Court found that the supposed inconsistent and inaccurate details in the testimonies of Ibacuado and Mallari were relatively trivial and minor. These discrepancies did not go into the substance of their testimonies, which coherently narrated the principal occurrence and established with certainty the identity of the petitioner as the perpetrator. The Court reiterated the doctrine that inconsistencies and inaccuracies in the testimony of a witness referring to minor details do not destroy credibility; on the contrary, they are often taken as badges of truth that bolster the probative value of the testimony. The eyewitness accounts, despite minor variations, consistently identified petitioner as the one who shot the victim. On the defense of alibi: The Court reiterated that alibi is the weakest of all defenses and must be received with suspicion. For alibi to be credible, the accused must positively demonstrate presence at another place and the physical impossibility of being at the locus criminis. The Court found that petitioner's alibi crumbled when weighed against the positive identification by credible witnesses. The testimonies of Ibacuado and Mallari were categorical, coherent, and consistent, and there was no showing of ill motive. The Court further noted that another witness, Jonathan Siluran, credibly refuted petitioner's alibi by testifying that he saw petitioner in his jeep on L. Lupa Street around the time of the incident. The bus tickets presented by petitioner were also viewed with suspicion due to their retention for a considerable length of time, which is contrary to customary practice.
Main Doctrine
Positive identification of the accused by credible witnesses prevails over alibi and denial, especially when the inconsistencies in the witnesses' testimonies refer to minor and insignificant details that do not affect the substance of their accounts. Furthermore, bus tickets presented to corroborate an alibi may be viewed with suspicion if their retention for a considerable length of time is not customary.