The Supreme Court affirmed that the silence of eyewitnesses for a considerable time does not automatically diminish their credibility, provided there is a sufficient explanation for the delay. The Court emphasized that fear or threat, as experienced in this case, can be a valid reason for initial silence. This ruling clarifies that a witness’s credibility should be evaluated based on the totality of circumstances, not solely on their promptness in reporting a crime.

When Fear Speaks Volumes: The Case of Ernesto Jamiro

The case revolves around the murder of Eduardo “Dado” Mulingbayan, where Ernesto Santiago Jamiro, a police officer, was accused of the crime. Several eyewitnesses, who had remained silent for nearly two years, came forward to testify against Jamiro. The core legal question was whether the delay in reporting the incident undermined the credibility of these witnesses, and whether their testimonies, along with the other evidence presented, were sufficient to convict Jamiro beyond a reasonable doubt.

The defense argued that the witnesses’ silence was contrary to normal human behavior, casting doubt on their testimonies. However, the Supreme Court rejected this argument, emphasizing that there is no standard reaction to shocking events. As the Court stated:

Time and again, this Court has ruled that, when confronted with startling occurrences, behavioral responses of witnesses are diverse. Indeed, there is no uniform reaction or standard behavioral response to grisly events.

The Court acknowledged that fear of reprisal, especially when the accused is a law enforcement officer, is a legitimate reason for remaining silent. The testimonies revealed that Jamiro had threatened the witnesses after the shooting, which further justified their initial reluctance to come forward. The Court emphasized that neither substantive nor procedural law requires a witness to immediately report a crime. The Supreme Court referenced People vs. Reoveros, stating that “the lapse of a considerable length of time before a witness comes forward to reveal the identity of the assailant does not taint the credibility of the witness and his testimony where such delay is satisfactorily explained.” Furthermore, it was explained that once apprehension is overcome by a desire to speak the truth, the witness must be welcomed by the courts in order that truth may be ascertained and justice dispensed.

The defense also pointed to inconsistencies between the eyewitness accounts and the expert testimony of the medico-legal officer. The defense highlighted that Dr. Garcia opined that the assailant was “standing on the same level or direction with the right side of the deceased.” However, the trajectory of the bullet was “slightly backward, slightly downward and from right to left.” The argument was that this clashed with witness accounts that indicated the victim was seated when the shot occurred. The Supreme Court dismissed these concerns, stating there were no material inconsistencies that would discredit the eyewitnesses’ accounts that the appellant shot the victim.

Another point raised was that the witnesses gave differing accounts about what Appellant Jamiro uttered right after he shot Dado. Manaois testified that the accused told the witnesses to leave, while Fuentes said the appellant threatened to kill anyone who testified. Ortiz, meanwhile, claimed that Jamiro pointed his gun at the people who saw the incident and told them not to report what happened to the police. The Court ruled that these differences were minor and did not impair the credibility of the testimonies.

The defense attempted to impute ulterior motives to the prosecution witnesses, asserting that they were gang members seeking retaliation against Jamiro. The Court rejected this claim, noting that there was insufficient evidence to establish that the witnesses were motivated by a desire to retaliate against the policeman’s actions. The Court referenced People vs. Panganiban, and explained that in the absence of sufficient proof of improper motive, the presumption is that said witnesses were not so moved and their testimonies are thus entitled to full faith and credit. Additionally, the relatives of a victim would not implicate a person other than the real culprit; their motivation is to seek justice for the death of a loved one.

The Supreme Court also addressed the issue of treachery, which qualified the killing as murder. Treachery exists when the attack is carried out swiftly, deliberately, and unexpectedly, leaving the victim without an opportunity to defend themselves. In this case, Dado Mulingbayan was sitting and drinking beer when Jamiro suddenly appeared from behind and shot him. The Court found that the sudden and unexpected nature of the attack, combined with the victim’s defenseless state, constituted treachery.

Regarding damages, the trial court awarded compensatory, moral, and exemplary damages to the victim’s family. However, the Supreme Court modified this decision, noting that actual damages must be supported by competent proof, such as receipts. Since there was no concrete evidence to justify the list of expenses presented by the victim’s father, the Court did not affirm this award. However, the Court maintained the award of moral damages. The Supreme Court referenced Article 2217 of the Civil Code, finding sufficient basis based on the declaration of suffering from the victim’s family.

In summary, the Supreme Court affirmed the conviction of Ernesto Santiago Jamiro for murder, emphasizing that the credibility of eyewitnesses is not automatically undermined by their initial silence, especially when justified by fear or threat. The Court also reiterated the importance of establishing treachery in qualifying a killing as murder, and the need for competent proof to support claims for actual damages.

FAQs

What was the key issue in this case?	The key issue was whether the delay in reporting the crime by the eyewitnesses affected their credibility and whether the prosecution had proven the accused’s guilt beyond a reasonable doubt.
Why did the eyewitnesses delay reporting the crime?	The eyewitnesses explained that they were afraid of the accused, who was a police officer, and had threatened them after the shooting.
Did the court find inconsistencies in the witnesses’ testimonies?	The court acknowledged minor inconsistencies but deemed them inconsequential and not sufficient to discredit the witnesses’ overall testimonies.
What is treachery, and why was it relevant in this case?	Treachery is the deliberate employment of means to ensure the execution of a crime without risk to the offender. It was relevant because it qualified the killing as murder.
What kind of evidence is needed to prove actual damages?	To prove actual damages, the party seeking them must present competent proof, such as receipts, to substantiate the expenses incurred.
What was the final ruling of the Supreme Court?	The Supreme Court affirmed the conviction of Ernesto Santiago Jamiro for murder but modified the award of damages, upholding the civil indemnity and moral damages while deleting the other damages due to lack of evidence.
Can an eyewitness testimony convict a person?	Yes, eyewitness testimony is admitted as evidence, but the court must assess it. It can be a ground to convict if the testimonies are credible and consistent with the facts.
What does it mean to prove guilt beyond reasonable doubt?	To prove guilt beyond a reasonable doubt means that there is no other logical explanation to derive from the facts except that the accused committed the crime.

This case reinforces the principle that the assessment of a witness’s credibility must consider the unique circumstances surrounding their testimony, including potential fear or intimidation. It also serves as a reminder of the importance of presenting concrete evidence when claiming actual damages. These points highlight the need for a nuanced understanding of evidence and witness behavior in criminal proceedings.

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. Jamiro, G.R. No. 117576, September 18, 1997