In People v. Ranin, the Supreme Court affirmed the conviction of Resurreccion Ranin, Jr. for murder, emphasizing the weight of positive eyewitness identification over the defense of alibi. The Court underscored that minor inconsistencies in a witness’s testimony do not automatically discredit their entire account, particularly when the core details remain consistent. This decision clarifies the standard for evaluating eyewitness testimony and affirms that a credible eyewitness account can outweigh a defendant’s denial or alibi, provided the identification is categorical and consistent.

Did Inconsistencies in Testimony Undermine Justice for a Campus Shooting?

The case arose from the fatal shooting of Niño Calinao on the University of the Philippines Diliman campus. Lina de Castro, a lady guard, identified Resurreccion Ranin, Jr. as the shooter. Ranin was seen pacing near the victim while intermittently glancing at a photo in his pocket before the incident. He fired multiple shots at Calinao. De Castro’s testimony was crucial, but it contained some discrepancies regarding the timing of the shots and Ranin’s distance from the victim.

Ranin argued that these inconsistencies, combined with his physical limitations from prior injuries, cast reasonable doubt on his guilt. He claimed he had never been to UP and could not have fired the weapon. The defense pointed out that Ranin had injuries affecting the use of his hands. He showed difficulty bending his fingers to hold or use a gun, but these were contested by the prosecution. The defense claimed it was impossible for him to commit the crime. However, the prosecution maintained that de Castro’s identification was unwavering and corroborated by other evidence.

The trial court convicted Ranin. They considered the testimony of de Castro and other circumstantial evidence. This was affirmed by the Court of Appeals, leading to the Supreme Court review. The central legal question was whether the eyewitness’s positive identification was credible despite some inconsistencies. Also, whether that testimony could outweigh the appellant’s alibi and claims of physical incapacity. The Supreme Court emphasized that minor inconsistencies do not necessarily negate a witness’s credibility.

The Court acknowledged that witnesses might make mistakes. Minor variances often serve as badges of truth rather than falsehood. De Castro clearly described the sequence of events. This indicated that Ranin fired shots at Calinao while the victim was defenseless. The Court also addressed the fact that the trial judge who penned the decision was not the same judge who heard the testimonies. They affirmed that a judge could rely on the transcripts without violating due process.

Building on this principle, the Supreme Court highlighted that positive identification by a witness is a significant factor. In this case, it can outweigh alibi and denial. Ranin’s defense of alibi and claims of physical impossibility were deemed insufficient to overcome de Castro’s identification. The court found Ranin’s physical limitations did not definitively prove it was impossible for him to shoot the victim. Medical examinations did not completely rule out the use of his right hand, which de Castro specifically identified as the hand holding the gun.

Furthermore, the Court agreed with the lower courts that the crime was committed with treachery and evident premeditation. Ranin’s actions of observing the victim and then launching a sudden attack demonstrated a planned and deliberate act of violence. However, in light of Republic Act No. 9346, which prohibits the imposition of the death penalty, the Court reduced Ranin’s sentence to reclusion perpetua without eligibility for parole.

The Court also adjusted the damages awarded, reducing the actual damages to P42,000 and moral damages to P50,000. Additionally, the Court ordered Ranin to pay civil indemnity of P75,000 and exemplary damages of P25,000, citing the aggravating circumstance of treachery. The ruling underscores the enduring legal principle that credible eyewitness testimony, even with minor inconsistencies, can be the cornerstone of a criminal conviction. It affirms the importance of positive identification in Philippine jurisprudence, particularly when weighed against defenses of alibi or claims of physical impossibility.

FAQs

What was the key issue in this case?	The key issue was whether the eyewitness’s positive identification of the accused as the shooter was credible, despite minor inconsistencies in her testimony, and whether this identification outweighed the accused’s alibi and claims of physical inability to commit the crime.
What is the significance of positive identification in this case?	Positive identification by an eyewitness is considered strong evidence, and in this case, it outweighed the accused’s defense of alibi and claims of physical impossibility, leading to his conviction for murder.
How did the Court address the inconsistencies in the eyewitness testimony?	The Court held that minor inconsistencies in a witness’s testimony do not automatically discredit their entire account. It found the core details consistent and deemed the inconsistencies as badges of truth rather than falsehood.
What was the accused’s defense in this case?	The accused, Resurreccion Ranin, Jr., claimed he had never been to the University of the Philippines and that his physical injuries made it impossible for him to fire the gun, presenting an alibi and disputing his ability to commit the crime.
What is reclusion perpetua, and why was the death penalty not imposed?	Reclusion perpetua is a Philippine prison sentence of life imprisonment. The death penalty was not imposed because Republic Act No. 9346 prohibits the imposition of the death penalty in the Philippines.
What damages were awarded to the victim’s heirs in this case?	The Court awarded the victim’s heirs P42,000 as actual damages, P50,000 as moral damages, P75,000 as civil indemnity, and P25,000 as exemplary damages.
How did the Court consider the accused’s physical limitations?	The Court acknowledged the accused’s physical limitations but found that they did not definitively prove he was unable to fire the gun. Medical examinations did not entirely rule out the use of his right hand.
What role did treachery play in the Court’s decision?	The Court found that the crime was committed with treachery, as the victim was given no opportunity to defend himself, which qualified the offense as murder and supported the award of exemplary damages.

The decision in People v. Ranin reaffirms the significance of positive eyewitness identification in Philippine criminal law, setting a clear precedent for how courts should evaluate the credibility of witnesses and weigh their testimonies against the defenses presented by the accused. This case clarifies that minor inconsistencies do not necessarily invalidate a witness’s account, especially when the core elements are consistent and convincing.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People of the Philippines vs. Resurreccion Ranin, Jr. y Jamali, G.R. No. 173023, June 25, 2008