In People v. Ambatang, the Supreme Court affirmed the conviction of King Rex A. Ambatang for murder, emphasizing that positive identification by credible witnesses outweighs the defenses of denial and alibi. This ruling underscores the importance of eyewitness testimony in Philippine criminal law, particularly when the witnesses have no apparent motive to falsely accuse the defendant. The decision reinforces the principle that factual findings of trial courts, especially concerning witness credibility, are given great weight unless substantial errors are shown. The court also highlighted that minor inconsistencies in witness statements do not necessarily undermine their credibility, provided they do not pertain to the central fact of the crime.

Stones, Knives, and Witness Accounts: Did Ambatang Commit Murder?

The case revolves around the events of October 17, 2002, in Taguig City, when Ely Vidal was fatally stabbed. The prosecution presented Jennifer Vidal Mateo and Romeo Acaba, who testified they saw Ambatang stabbing Vidal. Jennifer recounted hearing stones being thrown at their house and witnessing Ambatang standing outside. Acaba, a barangay tanod, testified to seeing Ambatang sharpening a knife shortly before the incident and later witnessing the stabbing. Carmelita Vidal, the victim’s wife, testified that her husband identified Ambatang as his attacker moments before dying, stating, “Si King Rex sinaksak ako ng sinaksak.”

Ambatang, in his defense, claimed he was at AMA Computer Learning Center during the time of the incident and that he was home when barangay tanods arrived looking for someone else. He claimed he was arrested while walking home from a friend’s house. His alibi was supported by his mother and girlfriend, who testified that he was home when the stabbing occurred. However, the Regional Trial Court and the Court of Appeals found the testimonies of the prosecution witnesses more credible, leading to Ambatang’s conviction.

The Supreme Court reiterated the principle that factual findings of trial courts regarding the credibility of witnesses are generally respected. As stated in People v. De Jesus, “factual findings of the trial court and its evaluation of the credibility of witnesses and their testimonies are entitled to great respect and will not be disturbed on appeal, unless the trial court is shown to have overlooked, misapprehended, or misapplied any fact or circumstance of weight and substance.”

The court found no reason to overturn the lower courts’ decisions, emphasizing the positive and unequivocal identification of Ambatang by Jennifer and Acaba. The defense of alibi was deemed weak and unreliable, especially since it was corroborated mainly by relatives and friends of the accused. The Court of Appeals noted, “It is well settled that positive identification by the prosecution witnesses of the accused as perpetrators of the crime is entitled to greater weight than their denials and alibis.”

For the defense of alibi to succeed, the accused must prove not only that he was elsewhere at the time of the crime, but also that it was physically impossible for him to be at the crime scene. As the Court of Appeals pointed out, “for the defense of alibi to prosper, the accused must prove not only that he was at some other place at the time of the commission of the crime but also that it was physically impossible for him to be at the locus delicti or within its immediate vicinity.” In this case, Ambatang failed to prove such physical impossibility.

Accused-appellant also questioned inconsistencies in the statements of Jennifer and Acaba. However, the Supreme Court considered these inconsistencies minor and insufficient to undermine their credibility. According to People v. Bagaua, “a few discrepancies and inconsistencies in the testimonies of witnesses referring to minor details and not actually touching upon the central fact of the crime do not impair the credibility of the witnesses. Instead of weakening their testimonies, such inconsistencies tend to strengthen their credibility because they discount the possibility of their being rehearsed.”

The Court emphasized that the critical aspect was that both witnesses testified to seeing Ambatang stab Vidal. The failure to recover the murder weapon or questions regarding Ambatang’s apprehension were deemed insufficient to overturn the conviction. Finding the accused in possession of the murder weapon is not a prerequisite for conviction.

The qualifying circumstance of treachery was also present. The Regional Trial Court observed, “Accused employed treachery when he attacked the victim. This is shown by the suddenness of the attack against the unarmed victim, without the slightest provocation on the latter’s part and opportunity to defend himself.” Given that the victim was unarmed and older, the attack was deemed treacherous.

The Supreme Court referenced People v. Jugueta to increase the damages awarded, recognizing the heinous nature of the crime. The civil indemnity, moral damages, and exemplary damages were each increased to P100,000.00.

FAQs

What was the key issue in this case?	The key issue was whether the accused, King Rex A. Ambatang, was guilty beyond reasonable doubt of the crime of murder, considering the eyewitness testimonies and his defense of alibi. The Supreme Court ultimately affirmed his conviction, prioritizing the positive identification by the witnesses over his alibi.
What is the significance of positive identification in this case?	Positive identification by credible witnesses Jennifer Vidal Mateo and Romeo Acaba played a crucial role in the conviction. Their testimonies, which directly implicated Ambatang in the stabbing, were given more weight than his alibi and the corroborating testimonies of his relatives.
What is the role of alibi as a defense strategy?	Alibi is a weak defense unless the accused can prove that they were in another place at the time the crime was committed and that it was physically impossible for them to be present at the crime scene. In this case, Ambatang failed to provide sufficient evidence to support his alibi.
What does treachery mean in the context of murder?	Treachery means that the offender employed means, methods, or forms in the execution of the crime which tended directly and specially to ensure its execution, without risk to himself arising from the defense which the offended party might make. The sudden and unexpected attack on Ely Vidal, who was unarmed and older, qualified the killing as murder.
Why were there increased damages in this case?	The Supreme Court increased the damages awarded in accordance with the precedent set in People v. Jugueta, recognizing the heinousness of the crime. The increase in civil indemnity, moral damages, and exemplary damages aims to provide more adequate compensation to the victim’s heirs.
What happens if there are inconsistencies in witness statements?	Minor inconsistencies in witness testimonies do not necessarily invalidate their credibility, especially if they do not pertain to the central fact of the crime. Such inconsistencies can even strengthen credibility by showing that the testimonies were not rehearsed.
Is possessing the murder weapon necessary for a murder conviction?	No, finding the accused in possession of the murder weapon is not a prerequisite for a murder conviction. The testimonies of eyewitnesses and other circumstantial evidence can be sufficient to establish guilt beyond a reasonable doubt.
How do courts assess the credibility of witnesses?	Courts assess credibility based on various factors, including the witness’s demeanor, consistency of their statements, and the presence or absence of any motive to lie. Trial courts are given deference in assessing credibility because they can directly observe witnesses.

The Supreme Court’s decision in People v. Ambatang reinforces established principles in Philippine criminal law, particularly the weight given to positive identification by credible witnesses and the limitations of alibi as a defense. This case serves as a reminder of the importance of presenting strong, consistent evidence in criminal proceedings and the deference appellate courts give to the factual findings of trial courts.

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 v. Ambatang, G.R. No. 205855, March 29, 2017