In Dundee A. Viernes v. People of the Philippines, the Supreme Court acquitted the accused, Dundee Viernes, due to reasonable doubt. The Court found significant inconsistencies in the testimony of the prosecution’s key witness, Josefina dela Cruz, particularly regarding the location of the crime and whether any items were stolen. This ruling underscores the importance of consistent and credible witness testimony in establishing guilt beyond a reasonable doubt in criminal cases.

Conflicting Accounts: Did Robbery Truly Occur?

The case revolves around an alleged robbery on November 15, 1992, where Josefina dela Cruz and her husband, Ronaldo Lopango, were passengers on a jeepney. According to Josefina, four fellow passengers declared a hold-up. During the incident, Lopango resisted and was fatally stabbed. Initially, the Regional Trial Court (RTC) convicted Dundee Viernes of highway robbery under Presidential Decree (P.D.) No. 532. However, the Court of Appeals modified the decision, finding Viernes guilty of simple robbery under Article 294 of the Revised Penal Code.

The Supreme Court, however, scrutinized the evidence and found several critical inconsistencies in Josefina’s statements. These discrepancies raised significant doubts about the veracity of her claims. One major inconsistency pertained to the location of the incident. In her initial sworn statement to the Caloocan police, Josefina stated that the robbery occurred in Sta. Catalina, Caloocan City. However, in a subsequent statement to the Manila police, she claimed the incident happened on R. Papa Street in Manila. This shift in location cast doubt on the accuracy of her recollection of events.

Furthermore, there were contradictions regarding whether any items were actually stolen during the alleged robbery. In her first statement, Josefina explicitly stated that nothing was taken from her and her husband:

	x x x x
07. T:	Magkano ang particular na na-hold-up sa inyo?
S:	Wala pong naholdap sa amin dahil lumaban nga ang asawa ko.
	x x x x,

However, in her later statement to the Manila police, she claimed that P3,000.00 was stolen. At trial, she testified that her belongings were recovered except for the P3,000.00. These conflicting accounts significantly undermined her credibility as a witness.

The Supreme Court also noted a discrepancy regarding how Josefina fell from the jeepney. In her initial statement, she indicated that she fell off the jeepney while trying to get off with her husband. However, during her testimony, she stated that the petitioner, Dundee Viernes, pushed her off the vehicle. Such inconsistencies between her sworn statement and her testimony at the witness stand further weakened her credibility.

Article 293 of the Revised Penal Code defines robbery as an unlawful taking of personal property belonging to another, achieved either through violence or intimidation or using force. To convict an accused of robbery, the prosecution must prove beyond a reasonable doubt that the accused unlawfully took personal property belonging to another, using one of the means specified in Article 293. In this case, the inconsistencies in Josefina’s testimony created doubt as to whether a robbery, as defined by law, even occurred.

The Court also addressed the admissibility and weight of inconsistent statements. While it is generally accepted that discrepancies between a witness’s testimony and sworn statement do not automatically discredit them, this rule is not absolute. The Court cited the case of People v. Español, which states that inconsistencies become significant when they pertain to vital details that an eyewitness would not be expected to overlook or when the sworn statement contradicts the court testimony substantially.

While the general rule is that contradictions and discrepancies between the testimony of a witness and his sworn statement do not necessarily discredit him since ex parte statements are generally incomplete, the rule is not without exception as, e.g., when the omission in the sworn statement refers to a very important detail of the incident which the one relating the incident as an eyewitness would not be expected to fail to mention, or when the narration in the sworn statement substantially contradicts the testimony in court.

Given the significant inconsistencies in Josefina’s testimony, the Court found that her credibility was severely compromised. Her assertion that she forgot to mention the stolen bag due to her husband’s death was deemed unconvincing, especially since she specifically stated that nothing was stolen from them in her initial statement. The court emphasized that while a conviction can be based on the testimony of a single witness, that testimony must be credible and positive.

Ultimately, the Supreme Court sided with the petitioner, reinforcing the fundamental principle that the burden of proof lies with the prosecution to establish guilt beyond a reasonable doubt. The inconsistencies in Josefina’s testimony, coupled with the lack of corroborating evidence, did not meet this threshold. The Court referenced People v. Rodriguez, stating that such inconsistencies undermine a witness’ overall credibility.

The ruling in Dundee A. Viernes v. People of the Philippines serves as a critical reminder of the importance of consistent and credible witness testimony in criminal proceedings. It emphasizes the necessity for the prosecution to present compelling evidence that establishes guilt beyond a reasonable doubt, safeguarding the constitutional presumption of innocence.

FAQs

What was the key issue in this case?	The key issue was whether the guilt of Dundee Viernes was proven beyond a reasonable doubt, considering the inconsistencies in the testimony of the prosecution’s primary witness.
What was the initial charge against Dundee Viernes?	Dundee Viernes was initially charged with violation of Presidential Decree (P.D.) No. 532, the Anti-Piracy and Anti-Highway Robbery Law of 1974.
How did the Court of Appeals modify the trial court’s decision?	The Court of Appeals modified the trial court’s decision by finding Dundee Viernes guilty of simple robbery under Article 294 of the Revised Penal Code.
What were the major inconsistencies in Josefina dela Cruz’s testimony?	The major inconsistencies included the location of the robbery (Caloocan vs. Manila), whether any items were stolen, and how Josefina fell from the jeepney.
What did Josefina dela Cruz initially state about the stolen items?	In her initial sworn statement, Josefina stated that nothing was stolen from her and her husband during the alleged robbery.
How did the Supreme Court view the inconsistencies in Josefina’s testimony?	The Supreme Court viewed the inconsistencies as significant enough to undermine Josefina’s credibility, thereby raising reasonable doubt about Dundee Viernes’ guilt.
What legal principle did the Supreme Court emphasize in its decision?	The Supreme Court emphasized the principle that the prosecution must prove the accused’s guilt beyond a reasonable doubt, and that the accused is presumed innocent until proven guilty.
What was the final verdict in the case?	The Supreme Court acquitted Dundee Viernes of the charge of violation of P.D. No. 532 due to reasonable doubt.

The Supreme Court’s decision to acquit Dundee Viernes highlights the critical role of credible and consistent testimony in criminal proceedings. This case underscores the judiciary’s commitment to upholding the presumption of innocence and ensuring that convictions are based on solid, reliable evidence.

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: Viernes v. People, G.R. No. 161970, June 30, 2006