People v. Ambatang
REITERATIONFacts
The Antecedents: On October 17, 2002, at around 10:30 p.m., Jennifer Vidal Mateo heard stones being hurled at her house. Upon peeking, she saw accused-appellant King Rex Ambatang outside with another person. Barangay tanods were called and went to Ambatang's house. While a tanod spoke to Ambatang's mother, another tanod saw Ambatang sharpening a knife. Ambatang then disappeared and reappeared at the Vidals' house, where he was seen on top of Ely Vidal, repeatedly stabbing him with a kitchen knife. Ambatang fled but was apprehended by the tanods. The victim was pronounced dead on arrival at the hospital, with the post-mortem findings indicating stab wounds to the chest as the cause of death. Jennifer and Acaba testified to witnessing the stabbing. Vidal's wife testified that the victim identified Ambatang as his assailant. Procedural History: The Regional Trial Court (RTC) found Ambatang guilty of murder and sentenced him to reclusion perpetua, with awards for civil indemnity, actual damages, moral damages, and temperate damages. The Court of Appeals (CA) affirmed the conviction but modified the awards, including exemplary damages and deleting temperate damages. Ambatang appealed to the Supreme Court. The Petition: The accused-appellant questioned his conviction for murder.
Issue(s)
Whether accused-appellant King Rex A. Ambatang is guilty beyond reasonable doubt of murder. Whether the defense of alibi is sufficient to overcome the positive identification by prosecution witnesses. Whether minor inconsistencies in the testimonies of prosecution witnesses affect their credibility.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals with modifications, finding accused-appellant King Rex A. Ambatang guilty beyond reasonable doubt of murder and sentencing him to suffer the penalty of reclusion perpetua without eligibility for parole. The Court also increased the awards for civil indemnity, moral damages, and exemplary damages to ₱100,000.00 each.
Ratio Decidendi
On the guilt of accused-appellant for murder: The Court found that the testimonies of the prosecution witnesses, Jennifer and Acaba, provided positive, unequivocal, and categorical identification of the accused-appellant as the perpetrator of the stabbing. These testimonies were sufficient to establish guilt beyond reasonable doubt. The presence of treachery was also confirmed, as the attack was sudden, against an unarmed victim who had no opportunity to defend himself, and the accused was superior in built and strength. The Court reiterated that factual findings of the trial court and its evaluation of witness credibility are entitled to great respect and will not be disturbed on appeal unless there is a showing of overlooked, misapprehended, or misapplied facts of substance. On the defense of alibi: The Court rejected the accused-appellant's defense of alibi. It is a well-settled rule that alibi is a weak defense, especially when contradicted by positive identification. The accused-appellant's alibi was corroborated by his mother and girlfriend, who are considered interested parties and whose testimonies are viewed with suspicion. Furthermore, for an alibi to prosper, it must be proven that the accused was not only in another place but that it was physically impossible for him to be at the locus delicti, which was not sufficiently established in this case. On minor inconsistencies in witness testimonies: The Court held that minor discrepancies and inconsistencies in the testimonies of witnesses, particularly on minor details that do not affect the central fact of the crime, do not impair their credibility. Instead, such inconsistencies can even strengthen credibility by showing that the testimonies were not rehearsed. The crucial point was that both Jennifer and Acaba witnessed the accused-appellant stabbing the victim, regardless of minor variations in their accounts of the sequence of events or the exact number of stab wounds.
Main Doctrine
The defense of alibi is weak and unreliable when confronted with positive identification by credible witnesses. Minor inconsistencies in witness testimonies do not impair credibility, especially when they do not touch upon the central fact of the crime.