In the Philippine legal system, convictions for murder hinge significantly on the credibility of witnesses and the establishment of qualifying circumstances such as treachery. The Supreme Court, in People v. Teñoso, affirmed the conviction of two accused for murder, emphasizing the trial court’s role in assessing witness credibility and the importance of proving treachery beyond reasonable doubt. This decision underscores how appellate courts defer to trial courts in evaluating witness testimonies, and how the presence of treachery can elevate a killing to murder, impacting the severity of the penalty.

When Minor Inconsistencies Cannot Obscure the Truth: Examining Witness Accounts in a Murder Trial

The case of People of the Philippines vs. Albert Teñoso y Lopez and Edgardo Cocotan arose from the brutal killing of Rosito Sambrano, also known as “Jongjong.” The accused, Albert Teñoso and Edgardo Cocotan, were charged with murder following an incident on March 20, 2004, in San Nicolas, Pangasinan. The prosecution presented evidence indicating that Teñoso and Cocotan conspired to fatally shoot Sambrano. In contrast, the defense argued inconsistencies in the testimonies of the prosecution’s witnesses and denied any direct involvement in the crime.

At trial, the Regional Trial Court (RTC) convicted the accused of murder, a decision that the Court of Appeals (CA) affirmed with modifications, adding moral damages to the penalty. The accused then appealed to the Supreme Court (SC), questioning the credibility of the witnesses and the presence of qualifying circumstances. The SC, in its decision, meticulously addressed each point raised by the defense, ultimately upholding the CA’s ruling.

One of the central arguments raised by the accused was the inconsistency in the testimonies of the prosecution witnesses, particularly regarding who held the victim and who fired the shots. The defense highlighted that Arnold Torio testified that Teñoso held Jongjong’s right hand while Cocotan held the left, whereas Leoncio Salvador IV stated the opposite. Similarly, there were discrepancies about who shot the victim and the number of shots fired. However, the Court dismissed these as minor inconsistencies that did not detract from the witnesses’ overall credibility. The SC reiterated the established principle that minor inconsistencies do not necessarily discredit a witness, especially when the testimony is coherent and believable in its entirety.

“Inaccuracies may in fact suggest that the witness is telling the truth and has not been rehearsed as it is not to be expected that he will be able to remember every single detail of an incident with perfect or total recall.”^[28]

The defense also questioned the identification of Teñoso by Leoncio Saldivar IV, alleging vagueness. However, the Court noted that any initial vagueness was cured by Saldivar’s subsequent positive identification of Teñoso in court, further corroborated by witness Torio. The Court emphasized the importance of in-court identification, even if there were issues with out-of-court identification procedures.

Another critical aspect of the case was the establishment of treachery (alevosia) as a qualifying circumstance to elevate the crime to murder. The Supreme Court cited People v. Lumintigar, emphasizing the two conditions necessary to appreciate treachery: (1) the employment of means, methods, or forms of execution that give the person attacked no opportunity to defend himself or retaliate; and (2) that such means were deliberately and consciously adopted.^[35]

“An unexpected and sudden attack under circumstances which render the victim unable and unprepared to defend himself by reason of the suddenness and severity of the attack, constitutes alevosia.”

The prosecution successfully proved that Sambrano was shot while on his motorcycle, and the attack was swift and sudden, leaving him no chance to defend himself. After falling, he was further assaulted and restrained. Even as he tried to escape, the accused pursued and shot him from behind. These circumstances, the Court held, clearly demonstrated treachery.

The defenses of denial and alibi presented by the accused were deemed weak and insufficient to overcome the positive identification by the prosecution witnesses. The Court cited Domingo v. People, reinforcing the principle that denial, if unsubstantiated, carries little weight against credible affirmative testimony.

Regarding the civil liabilities, the Court upheld the award of P300,000.00 as civil indemnity, given that the parties had stipulated this amount in the event of a conviction. The standard amount awarded by jurisprudence is P50,000.00. Additionally, the awards for moral and exemplary damages were deemed appropriate due to the violent nature of the death and the presence of the aggravating circumstance of treachery. The Court also awarded exemplary damages of P30,000.00 to the heirs of the victim. These damages serve to compensate the victim’s family for their loss and to deter similar acts of violence.

The SC’s decision sheds light on the evidentiary standards in murder cases. The case underscores the importance of witness credibility, as primarily assessed by the trial court, and the significance of proving qualifying circumstances such as treachery. The decision also affirms the principles of civil liability and damages in criminal cases, emphasizing the need to compensate victims and deter future crimes. The presence of minor inconsistencies does not automatically discredit witnesses. The totality of their testimonies must be assessed to determine their truthfulness. Positive identification by credible witnesses is a powerful form of evidence, particularly when corroborated by other facts. The presence of treachery significantly impacts the outcome of a murder case, influencing both the conviction and the penalties imposed. The Supreme Court’s decision emphasizes the importance of these elements in the Philippine criminal justice system, providing guidance for future cases involving similar circumstances.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution successfully proved the guilt of the accused beyond reasonable doubt for the crime of murder, considering the alleged inconsistencies in the testimonies of the prosecution’s witnesses and the presence of qualifying circumstances such as treachery.
What is the significance of “treachery” in this case?	Treachery (alevosia) is a qualifying circumstance that elevates homicide to murder. It means the offender employed means of execution that ensured the victim had no opportunity to defend themselves, and that this method was deliberately adopted.
Why did the Supreme Court uphold the trial court’s assessment of witness credibility?	The Supreme Court generally defers to the trial court’s assessment of witness credibility because the trial court has the firsthand opportunity to observe the witnesses’ demeanor and conduct during trial. This provides a better basis for judging their truthfulness.
What weight did the Court give to inconsistencies in the witness testimonies?	The Court deemed the inconsistencies to be minor and insufficient to discredit the witnesses’ overall testimonies. It recognized that minor discrepancies are common and do not necessarily indicate falsehood, especially when the main points of the testimony remain consistent.
How did the Court address the accused’s defenses of denial and alibi?	The Court found the defenses of denial and alibi to be weak and unsubstantiated. It reiterated that such defenses are inherently self-serving and cannot outweigh the positive identification of the accused by credible witnesses.
What are civil indemnity, moral damages, and exemplary damages?	Civil indemnity is compensation for the victim’s death, awarded automatically upon conviction. Moral damages compensate for the victim’s pain and suffering, and the victim’s family’s emotional distress. Exemplary damages are awarded to deter similar conduct, especially when an aggravating circumstance is present.
Why was the civil indemnity set at P300,000.00 instead of the usual P50,000.00?	The civil indemnity was set at P300,000.00 because the parties had stipulated that amount in the event of a conviction. This stipulation was binding on the Court, even though jurisprudence typically sets the amount at P50,000.00.
What is the significance of positive identification in criminal cases?	Positive identification, when made by credible witnesses, is a strong form of evidence that can establish the accused’s guilt beyond a reasonable doubt. It means the witness specifically and unequivocally identified the accused as the perpetrator of the crime.

In conclusion, the People v. Teñoso case reinforces several key principles in Philippine criminal law, including the importance of witness credibility, the significance of proving treachery in murder cases, and the application of civil liabilities and damages. The decision underscores the judiciary’s commitment to ensuring justice for victims of violent crimes while upholding the rights of the accused.

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, Appellee, vs. Albert Teñoso y Lopez Alias “Paking” and Edgardo Cocotan Alias “Paot,” Appellants., G.R. No. 188975, July 05, 2010