The Supreme Court ruled that a witness’s inaction during a crime, stemming from shock or fear, does not automatically render their testimony incredible. This decision reinforces that individuals react differently to startling events, and a witness’s failure to intervene does not inherently undermine their reliability in recounting the events they observed. The court emphasized that assessing witness credibility requires considering the specific circumstances and acknowledging the varied human responses to shocking situations. This nuanced approach ensures that testimonies are evaluated fairly, accounting for the psychological impact of witnessing a crime.

When Shock Silences: Assessing Witness Testimony in a Murder Case

The case of People v. Jesus Muyco revolves around the murder of Romeo Boteja Jr., where Jesus Muyco was convicted based on the testimony of Ernesto Boteja, an eyewitness. Muyco appealed the conviction, arguing that Ernesto’s testimony was improbable because Ernesto did not react when Romeo was stabbed. The central legal question is whether Ernesto’s inaction due to shock undermines his credibility as a witness.

The accused-appellant contended that the court a quo erred in lending credence to the testimony of Ernesto Boteja, arguing that his inaction when his nephew Romeo was stabbed just a meter away from him is contrary to human nature. However, the Supreme Court disagreed. The court emphasized that different people react differently to a given type of situation.

The Supreme Court has consistently held that there is no standard form of human behavioral response when one is confronted with a strange, startling, or frightful experience. As the Supreme Court stated in *People v. Roncal*:

One person’s spontaneous or unthinking, or even instinctive response to a horrid and repulsive stimulus may be aggression, while another person’s reaction may be cold indifference.

Applying this principle, the court found that Ernesto’s inability to move, help, or even run away when the incident occurred is not a ground to label his testimony as doubtful and unworthy of belief. There is no prescribed behavior when one is faced with a shocking event. The court understood Ernesto Boteja’s inability to react, explaining that he was shocked by the suddenness of the event and considering that it was his first time to witness a stabbing incident.

Furthermore, the accused-appellant cited inconsistencies in the testimony of Ernesto. However, the Supreme Court found no inconsistencies after a close scrutiny of the records. The accused-appellant pointed out that Ernesto testified having seen the victim stabbed on his neck instead of his collarbone. However, Dr. Jaboneta, who autopsied the body of the victim, explained that the wound inflicted was just below the collarbone. The Supreme Court held that for a layman like Ernesto, who does not have any medical background at all, there is little or no material difference between a neck and a collarbone.

Moreover, it would be too much to expect Ernesto to be perfectly accurate in reporting the location of the wound considering the circumstances surrounding the incident. Inconsistencies and discrepancies in the testimony of a witness on minor details only serve to strengthen the credibility of the witness. As stated in *People v. Atad*:

Inconsistencies and discrepancies in the testimony of a witness on minor details only serve to strenthen the credibility of the witness.

The Supreme Court has also ruled that discrepancies in minor details indicate veracity rather than prevarication. They tend to bolster the probative value of the testimony being questioned. They enhance, rather than destroy, the witness’s credibility and the truthfulness of his testimony as they erase any suspicion of being a rehearsed testimony. As stated in *People v. Fabrigas*:

This Court has ruled often enough that discrepancies in minor details indicate veracity rather than prevarication. They tend to bolster the probative value of the testimony being questioned. They enhance, rather than destroy, the witness’ credibility and the truthfulness of his testimony as they erase any suspicion of being a rehearsed testimony.

The Supreme Court reiterated that the prosecution has overcome the accused-appellant’s presumed innocence and satisfactorily established his guilt beyond reasonable doubt. His alibi could not be given any weight at all in view of his positive identification by the prosecution’s eyewitness. No ill motive was imputed to Ernesto Boteja that would so move him to falsely testify against accused-appellant. The trial court properly assessed his testimony as credible and trustworthy.

The accused-appellant’s alibi became all the more ineffectual when he failed to demonstrate that it was physically impossible for him to be at the crime scene at the time it was committed. He testified being in Passi, Iloilo, during the stabbing incident. Passi, Iloilo is only fifty (50) kilometers from Cabatuan, Iloilo, the place where the crime was committed. He did not offer any evidence to prove impossibility of access between the two (2) places when the crime transpired.

Finally, the Supreme Court agreed with the court below that treachery attended the commission of the crime. The evidence amply proves that Romeo Boteja Jr. was killed in a manner ensuring suddenness and surprise that virtually incapacitated the victim from offering any resistance or defense. The victim did not have any inkling of the lurking danger to his life. He might have felt at ease with Jesus and Arnulfo for he had been drinking with them since 6:00 o’clock that evening of 13 May 1995 until he was stabbed to death. The attack was so sudden and unexpected that the victim failed to offer any resistance at all. All he could do was to struggle faintly against his attackers.

FAQs

What was the key issue in this case?	The key issue was whether an eyewitness’s failure to react during a stabbing incident due to shock undermined their credibility as a witness.
Why did the accused-appellant challenge the witness’s testimony?	The accused-appellant challenged the witness’s testimony because the witness did not immediately react or intervene when the victim was stabbed, arguing that this inaction was contrary to human nature.
What did the Supreme Court say about different reactions to shocking events?	The Supreme Court stated that people react differently to shocking events, and there is no standard behavioral response. Some may become aggressive, while others may freeze.
Did the court find any inconsistencies in the witness’s testimony?	No, the court found no significant inconsistencies. The discrepancy between describing the wound location as the neck versus the collarbone was considered minor for a layperson.
What role did the accused-appellant’s alibi play in the decision?	The accused-appellant’s alibi was deemed weak because he failed to prove it was physically impossible for him to be at the crime scene, given the proximity of Passi, Iloilo, to Cabatuan, Iloilo.
How did the court determine that treachery was present in the commission of the crime?	The court determined that treachery was present because the attack was sudden and unexpected, leaving the victim unable to defend himself.
What is the practical implication of this ruling for future cases?	The ruling clarifies that witness credibility should be assessed considering individual reactions to shocking events, preventing unfair dismissal of testimonies based solely on a lack of immediate response.
What kind of evidence did the prosecution present?	The prosecution presented eyewitness testimony, forensic evidence (autopsy report), and testimonies from individuals who saw the accused and victim together before the incident.

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. Jesus Muyco, G.R. No. 132252, April 27, 2000