People v. Soriano
REITERATIONFacts
The Antecedents: On May 2, 2001, at Barangay Oraan West, Manaoag, Pangasinan, Diodito Broniola was shot twice and died. The Information charged Rodolfo "Rudy" Soriano (appellant) and Ireneo "Rene" Lumilay with murder, alleging conspiracy, use of unlicensed firearms, intent to kill, treachery, and evident premeditation. Procedural History: Appellant was arrested, while Lumilay remained at large. Upon arraignment, appellant pleaded not guilty. The prosecution presented eyewitness Genaro R. Lumilay, police investigator PO3 Dante N. Marmolejo, and Rural Health Physician Dr. Arnulfo T. Bacorro. Genaro testified that while walking home with Diodito and Rowena P. Cariño, appellant and Ireneo emerged and appellant shot Diodito below the neck, and Ireneo shot him again as he fell. Dr. Bacorro's autopsy revealed two fatal gunshot wounds. The defense presented appellant, his wife Elvira Soriano, and Edwina C. de Jesus. Elvira and appellant claimed they were at home and heard the gunshot, then saw Genaro running and Diodito on the ground. Elvira suggested Genaro had ill motive due to a borrowed duck and appellant's closeness to Ireneo (who won a land dispute against Genaro's father) and Jonathan Fernandez (private complainant in a robbery case against Genaro). Edwina testified she heard a shout and a gunshot but did not see appellant at the scene. The RTC found appellant guilty of murder, appreciating treachery, and sentenced him to reclusion perpetua. The Court of Appeals affirmed the RTC decision. The Petition: Appellant appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, primarily questioning the credibility of the lone eyewitness, Genaro R. Lumilay, due to alleged ill motive and the failure to present another eyewitness, Rowena P. Cariño.
Issue(s)
Whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt. Whether the trial court erred in relying on the testimony of the lone eyewitness, Genaro R. Lumilay, despite allegations of ill motive. Whether the failure to present Rowena P. Cariño as a witness is fatal to the prosecution's case. Whether treachery attended the killing.
Ruling
The appeal is denied. The Decision of the Court of Appeals, which affirmed the RTC's conviction of appellant Rodolfo "Rudy" Soriano for murder, is AFFIRMED.
Ratio Decidendi
On the issue of whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt: The Court held that the appeal lacks merit. The assigned error primarily concerned the trial court's assessment of witness credibility. The established doctrine is that the assessment of witness credibility lies within the province of trial courts, and appellate courts will not disturb this unless there is a clear showing of arbitrary oversight or disregard of significant facts and circumstances. The records did not show any exceptions to this rule in the present case. Therefore, the prosecution successfully proved appellant's guilt beyond reasonable doubt. On the issue of whether the trial court erred in relying on the testimony of the lone eyewitness, Genaro R. Lumilay, despite allegations of ill motive: The Court rejected appellant's argument that Genaro was impelled by ill motive. The records were barren of satisfactory proof to show such bias. The trial court gave credence to Genaro's testimony because his statement was taken immediately after the incident, indicating no time for fabrication. Furthermore, Genaro withstood cross-examination and remained consistent. The Court of Appeals also found the alleged ill motive speculative. The Court noted that any ill motive Genaro might have had would likely be directed towards Ireneo, not appellant, as the land dispute was between Genaro's father and Ireneo, and the robbery case against Genaro did not involve appellant. Thus, the trial court did not err in relying on Genaro's testimony. On the issue of whether the failure to present Rowena P. Cariño as a witness is fatal to the prosecution's case: The Court reiterated the rule that the prosecution has the exclusive prerogative to determine whom to present as witnesses. It need not present every witness, only those necessary to meet the quantum of proof required for conviction. The non-presentation of corroborative witnesses is not suppression of evidence and is not fatal to the prosecution's case. Rowena was equally available to the defense, thus no negative inference could be made from her non-presentation. The prosecution's case was sufficiently established by Genaro's testimony and the medical findings. On the issue of whether treachery attended the killing: The trial court appreciated treachery, qualifying the killing to murder, ruling that Diodito was attacked in a swift and unexpected manner, affording him no chance to defend himself. The Court of Appeals affirmed this, noting that Diodito and his companions were walking when appellant suddenly appeared and shot him, consciously adopting a mode of attack to ensure success without risk. Diodito was unaware and unable to defend himself. The appellate court found treachery present due to the suddenness of the attack and the absence of an opportunity for Diodito to repel it. This finding was consistent with the evidence presented.
Main Doctrine
The assessment of the credibility of witnesses lies within the province and competence of trial courts, and appellate courts will not disturb such assessment unless it is clearly shown that the trial court has overlooked or disregarded arbitrarily facts and circumstances of significance. The testimony of a single, trustworthy and credible witness is sufficient for conviction.