In People v. Bajada, the Supreme Court affirmed the conviction of Nestor Bajada for robbery with homicide, emphasizing the weight given to consistent eyewitness identification despite minor inconsistencies in initial statements. This case clarifies that minor discrepancies between sworn statements and testimonies do not automatically discredit an eyewitness, particularly when the core identification remains consistent and the witness is familiar with the accused.

Familiar Faces, Fatal Night: Can Prior Acquaintance Overcome Witness Statement Flaws?

This case revolves around the tragic events of December 22, 1999, in Liliw, Laguna, when Antonio Villamayor was killed during a robbery at his home. Anabelle Asaytono, Villamayor’s live-in partner, identified Nestor Bajada and Victor Calisay, acquaintances from Villamayor’s farm, as two of the perpetrators. The pivotal legal question was whether Asaytono’s identification of the accused was credible enough to secure a conviction, considering inconsistencies between her initial sworn statements and her testimony in court.

The defense argued that Asaytono’s testimony was unreliable due to inconsistencies regarding details such as the identity of the caller, the alleged intoxication of the accused, and specifics of how she identified them. Bajada contended that these discrepancies cast doubt on his guilt, suggesting that the identification process was flawed and potentially motivated by Asaytono’s ulterior motives. He even submitted a letter from an alleged eyewitness, which the court did not admit. However, the Court emphasized the significance of Asaytono’s consistent identification of Bajada and Calisay as the perpetrators throughout her statements and testimony. According to the Court, trivial details that evolved were acceptable. The key element remained her certainty in recognizing them.

Credibility of the witness is important. The Court cited People v. Castillano, Sr., stating that a witness must be given a chance to recollect and explain the apparent inconsistency between his two statements and state the circumstances under which they were made to prevent injustice to the witness being cross-examined.

Section 13, Rule 132 of the Revised Rules of Court states:

Section 13. How witness impeached by evidence of inconsistent statements.–Before a witness can be impeached by evidence that he has made at other times statements inconsistent with his present testimony, the statements must be related to him, with the circumstances of the times and places and the persons present, and he must be asked whether he made such statements, and if so, allowed to explain them. If the statements be in writing, they must be shown to the witness before any question is put to him concerning them.

The court highlighted that the defense failed to confront Asaytono with these supposed inconsistencies during cross-examination, thus undermining their argument. Citing People v. Alegado, the court reiterated that sworn statements are often considered inferior to testimony in open court. Because of the potential for incomplete or coached information, court testimony is considered more thoroughly examined.

Another key factor in the court’s decision was Asaytono’s familiarity with Bajada and Calisay. Having known them for over a year and recognizing their physical characteristics from their frequent visits to Villamayor’s house, the court found her identification credible. The court generally defers to the trial court’s assessment of a witness’s demeanor and credibility, given the trial court’s opportunity to directly observe the witness.

Bajada’s defense of alibi was weakened by his admission that the crime scene was only a 15-minute jeep ride from where he claimed to be at the time of the robbery. In cases of alibi, the accused must prove that it was physically impossible for him to be present at the crime scene when the crime happened. This timeline undermined Bajada’s defense, reinforcing the prosecution’s case against him. Moreover, the court found no credible ill motive on Asaytono’s part to falsely accuse Bajada. The alleged motive of inheriting from Villamayor was unsubstantiated and deemed self-serving.

The CA adjusted the penalty from death to reclusion perpetua. The trial court found dwelling was an aggravating circumstance, but this was not alleged in the information. Further, physical injuries are not a separate charge in a case of robbery with homicide.

FAQs

What was the key issue in this case?	The key issue was whether the eyewitness’s identification of the accused was credible, given inconsistencies between her initial statements and her testimony in court. The court emphasized the importance of consistent identification, even if details evolved over time.
What is robbery with homicide?	Robbery with homicide is a crime where a robbery occurs, and, during the robbery, a person is killed. It is a single, indivisible offense, regardless of how the homicide is perpetrated.
What is ‘reclusion perpetua’?	Reclusion perpetua is a Philippine prison sentence that typically means imprisonment for at least 20 years and one day, up to a maximum of 40 years. It also carries accessory penalties like perpetual absolute disqualification.
Why was the original death penalty reduced?	The death penalty was reduced to reclusion perpetua because the aggravating circumstance of dwelling was not specifically alleged in the information. Also, physical injuries in robbery with homicide are not a separate crime.
What did the court say about inconsistencies in witness statements?	The court stated that inconsistencies between a sworn statement and court testimony do not automatically discredit a witness. As long as the core identification remains consistent, minor inconsistencies are viewed as trivial and do not negate the witness’s credibility.
What is the significance of familiarity with the accused?	Familiarity with the accused, such as knowing their physical features and mannerisms, strengthens the credibility of the eyewitness’s identification. Prior acquaintance helps to eliminate the possibility of mistaken identity.
What is the defense of alibi?	Alibi is a defense that claims the accused was elsewhere when the crime occurred, making it impossible for them to commit the crime. For alibi to succeed, the accused must prove they were in a different location and that it was physically impossible to be at the crime scene.
What should be proven with an alibi?	For alibi to prosper, it must be shown that the accused was somewhere else at the time of the commission of the offense and that it was physically impossible for the accused to be present at the scene of the crime at the time of its commission.

The Supreme Court’s decision in People v. Bajada highlights the judiciary’s approach to evaluating eyewitness testimony in criminal cases. This ruling illustrates that familiarity and consistency are key components of a witness account that can stand against challenges of potentially inconsistent testimony.

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. Nestor Bajada y Bautista, G.R. No. 180507, November 20, 2008