This case has been cited 9 times or more.
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2010-12-14 |
ABAD, J. |
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| I find that the circumstances of habitual drug use and delay in reporting a crime did not affect the competence and credibility of prosecution witness Alfaro. It bears stressing that the fact of delay alone does not work against the witnesses. Delay or vacillation in making a criminal accusation does not necessarily impair the credibility of the witness if such delay is satisfactorily explained.[116] | |||||
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2010-02-01 |
DEL CASTILLO, J. |
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| One thing which bolsters the prosecution witnesses' credibility is the fact that they had no motive to prevaricate against the petitioners. They were not actuated by improper motive to fabricate the facts and to foist a very serious offense against them. Where there is no evidence, as in this case, to indicate that the prosecution witnesses were actuated by improper motive, the presumption is that they were not so actuated and that their testimonies are entitled to full faith and credit.[12] For personal motive on the part of a witness to testify against the accused to be appreciated as showing bias, its presence should be supported by satisfactory proof.[13] Aside from their bare allegation, petitioners miserably failed in this regard. On the contrary, we are not prepared to disbelieve the prosecution witnesses' testimonies on their vital points substantiating the circumstances of time and place of the offense charged against petitioners. | |||||
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2009-10-16 |
LEONARDO-DE CASTRO, J. |
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| Accused-appellant attempts to deflect culpability to Alvin and Jomar by pointing out that they were the ones who went into hiding right after the incident. As the Court held in People v. Simon,[28] however, different people react differently to a given situation, and there is no standard form of behavioral response when one is confronted with a strange, startling, or frightful experience. In this case, we take into account the fact that Alvin and Jomar were still minors at the time they witnessed accused-appellant's brutality. Moreover, accused-appellant threatened to kill said witnesses if they reported the matter to the authorities, as shown in Alvin's testimony below: Q And, after you were able to [dispose of] the body of the deceased, what happened afterwards? A I and Jomar were led off by Bong and we were told by Bong not to tell anything to the police because he is going to kill us, Sir. | |||||
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2008-10-29 |
CHICO-NAZARIO, J. |
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| It is settled that aggravating/qualifying circumstances must be alleged in the information and proven during the trial before they can be appreciated.[51] | |||||
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2007-09-03 |
GARCIA, J. |
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| The Court joins the trial court's assessment of the credibility and candor of Edgar's testimony. The legal aphorism is that factual findings of the trial court, its calibration of the testimonies of the witnesses and its assessment of their probative weight are given high respect if not conclusive effect, unless it ignored, misconstrued, misunderstood or misinterpreted cogent facts and circumstances of substance, which, if considered, will alter the outcome of the case.[23] We find none in this case. The trial court is in the best position to ascertain and measure the sincerity and spontaneity of witnesses through its actual observation of the witnesses' manner of testifying, demeanor and behavior while in the witness box.[24] | |||||
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2007-06-07 |
QUISUMBING, J. |
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| When treachery is present, an allegation of abuse of superior strength can no longer be appreciated as an independent aggravating circumstance.[50] The same holds true with the circumstance of disregard of the respect on account of rank, age or sex, which in this case could not be aggravating.[51] In like manner, we do not find that disguise, fraud or craft attended the commission of the crimes. Also, we find no intellectual trickery nor cunning resorted to by appellant to lure his victims into a trap and conceal his identity.[52] | |||||
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2007-01-26 |
CHICO-NAZARIO, J. |
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| On another point, we agree with the penalty imposed by the Court of Appeals. Article 248 of the Revised Penal Code states that murder is punishable by reclusion perpetua to death. Article 63 of the same Code provides that if the penalty is composed of two indivisible penalties, as in the instant case, and there are no aggravating or mitigating circumstances, the lesser penalty shall be applied. Since there is no mitigating or aggravating circumstance in the present case, and, treachery cannot be considered as an aggravating circumstance as it was already taken as a qualifying circumstance, the lesser penalty of reclusion perpetua should be imposed. As regards the damages awarded by the Court of Appeals, we rule that the sum of P35,470.00 as actual damages should be reduced to P25,670.00 since the receipts on record amounts only to P25,670.00.[45] It is well-settled that only expenses supported by receipts will be allowed for actual damages.[46] Furthermore, exemplary damages should also be awarded to the heirs of Michael since the qualifying circumstance of treachery was firmly established by the prosecution.[47] If a crime is committed with an aggravating circumstance, either qualifying or generic, an award of P25,000.00 as exemplary damages is justified under Article 2230 of the New Civil Code.[48] This kind of damage is intended to serve as a deterrent to serious wrongdoings, and as a vindication of undue sufferings and wanton invasion of the rights of an injured person or punishment for those guilty of outrageous conduct.[49] | |||||
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2006-12-06 |
CHICO-NAZARIO, J. |
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| The fact that Simplicio did not immediately give a sworn statement to the authorities about the incident and his initial hesitation to testify in court on the same does not necessarily destroy the genuineness of his testimony. Witnesses are usually reluctant to volunteer information about a criminal case or are unwilling to be involved in or dragged into criminal investigations due to a variety of valid reasons.[32] Fear of reprisal and the natural reluctance of a witness to get involved in a criminal case are sufficient explanations for a witness' delay in reporting the crime to authorities.[33] After the incident, Simplicio feared for his and his family's safety if he testified against appellant. It is only after the lapse of one year that he agreed to divulge information about the incident in order to make sure that the possibility of a threat to his life or his loved ones is already diminished, if not totally avoided. Furthermore, no ill-motive can be imputed to Simplicio for testifying against appellant. Appellant himself admitted that he does not know of any reason why Simplicio would testify against him.[34] | |||||
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2006-02-28 |
CHICO-NAZARIO, J. |
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| This argument does not inspire belief. The blood relationship of Armando Maramba and private complainant would not render the former's testimony unworthy of belief. On the contrary, relationship could strengthen the witnesses' credibility, for it is unnatural for an aggrieved relative to falsely accuse someone other than the actual culprit. Their natural interest in securing the conviction of the guilty would deter them from implicating a person other than the true offender.[42] It is settled that where there is no evidence and nothing to indicate that the principal witnesses for the prosecution were actuated by improper motive, the presumption is that they were not so actuated and their testimonies are entitled to full faith and credit.[43] The weight of the testimony of witnesses is not impaired nor in anyway affected by their relationship to the victim when there is no showing of improper motive on their part.[44] Jurisprudence likewise holds that if an accused had really nothing to do with a crime, it would be against the natural order of events and of human nature, and against the presumption of good faith, that a prosecution witness would falsely testify against him.[45] In the case before us, aside from petitioner's claim that he was framed-up, there is nothing in the records that shows that Armando Maramba had ulterior motives in testifying against him. Necessarily, the testimony of Armando Maramba must be given full credit. | |||||