In the case of Nestor B. Decasa v. Court of Appeals and People, the Supreme Court affirmed the conviction of Nestor B. Decasa for homicide, emphasizing that inconsistencies between a witness’s affidavit and their court testimony do not automatically discredit their account. This ruling underscores the importance of evaluating the credibility and overall consistency of witness testimonies, as discrepancies in affidavits are common and often seen as secondary to in-court declarations. The decision ensures that convictions can still be upheld based on reliable eyewitness accounts, even if initial statements contain omissions or variations.
Moonlight and Murder: Evaluating Eyewitness Credibility Despite Inconsistencies
The narrative unfolds in Bilar, Bohol, where Nestor B. Decasa was accused of fatally stabbing Teodoro Luzano over a dispute about water for their ricefields. Rogelio Boco, the key eyewitness, testified that he saw Decasa attack Luzano. Crucially, Decasa challenged Boco’s credibility, pointing out that Boco’s initial affidavit didn’t mention he actually witnessed the stabbing. The defense argued this omission, along with other minor inconsistencies, should cast doubt on Boco’s entire testimony. The Regional Trial Court (RTC) convicted Decasa, a decision affirmed by the Court of Appeals, leading to this appeal before the Supreme Court. The central legal question was whether these inconsistencies undermined the eyewitness account enough to overturn the conviction.
The Supreme Court began its analysis by addressing the apparent discrepancies in Rogelio Boco’s statements. The Court acknowledged the differences between Boco’s affidavit and his testimony but emphasized that such inconsistencies are not necessarily fatal to his credibility. The Court highlighted Boco’s explanation that he believed his affidavit already included the detail of witnessing the hacking. This explanation was deemed reasonable, as witnesses, especially those recounting traumatic events, may not always provide flawless accounts. As the Court noted, “witnesses cannot be expected to give a flawless testimony all the time. This is even more true if they are called to testify on details of a harrowing and frightening event which unfolded before their eyes.”
Furthermore, the Court reiterated a well-established principle that sworn statements taken ex parte are generally considered inferior to testimonies given in open court. Affidavits are often incomplete and do not capture the full context of an event. Therefore, discrepancies between an affidavit and in-court testimony do not automatically discredit a witness. The Court has consistently ruled that such discrepancies are not fatal defects justifying the reversal of a judgment as
“ex-parte affidavits are almost always incomplete. A sworn statement or an affidavit does [not] purport to contain a complete compendium of the details of the event narrated by the affiant. Sworn statements taken ex parte are generally considered to be inferior to the testimony given in open court.”
Building on this principle, the Court considered the consistency of Boco’s testimony with other evidence. Notably, Boco’s account of the attack aligned with the findings of Dr. Maria Nenita Tumanda, who conducted the post-mortem examination. Boco stated that Decasa hacked Luzano on the head with a bolo-like instrument, and Dr. Tumanda confirmed that the victim’s injuries were consistent with such a weapon. This corroboration significantly bolstered Boco’s credibility. It underscored the reliability of his testimony despite the initial omission in his affidavit.
Decasa also argued that Boco had an ill motive against him, which should discredit his testimony. The Court dismissed this argument, stating that the existence of a grudge does not automatically render a witness’s testimony false, especially when the witness provides a direct account of the crime. Moreover, the Court noted that the prior conflict between Decasa and Boco had been settled before their Barangay Council, diminishing the significance of any alleged ill motive. The Court emphasized that “Motive is essential for conviction when there is doubt as to the identity of the culprit.” In cases where the identity of the perpetrator is clear, motive becomes less critical.
The Court also addressed the inconsistencies regarding the moonlight on the night of the incident and Boco’s habit of gathering tuba at night. Decasa presented calendar evidence to show that the moon was not full on the night of the crime. However, the Court found this detail insignificant, given that Boco was only five meters away from the incident and familiar with the parties involved. Similarly, the Court dismissed the argument that Boco’s testimony about his tuba-gathering habits was inconsistent. The Court focused on the core testimony that Boco witnessed the hacking, deeming minor discrepancies irrelevant. The Court was clear in its pronouncements, stating that these “discrepancies only erase suspicion that the testimony was rehearsed or concocted. These honest inconsistencies serve to strengthen rather than destroy Rogelio’s credibility.”
A significant aspect of Decasa’s appeal was that Judge Calibo, who rendered the decision, did not hear the majority of the prosecution’s evidence. Judge Calibo took over the case after Judge Melicor inhibited himself. The Supreme Court acknowledged that it is preferable for the judge who hears the evidence to render the judgment. However, the Court emphasized that a judge can validly decide a case based on the records, transcripts, and evidence presented, even if they did not personally hear all the testimonies. Judge Calibo, in this case, also conducted an ocular inspection of the crime scene, further enhancing his understanding of the case. Thus, the Court stated that “the efficacy of a decision is not necessarily impaired by the fact that its writer only took over from a colleague who had earlier presided at the trial. That a judge did not hear a case does not necessarily render him less competent in assessing the credibility of witnesses. He can rely on the transcripts of stenographic notes of their testimony and calibrate them in accordance with their conformity to common experience, knowledge and observation of ordinary men.”
Decasa also claimed that Judge Calibo was biased because he had previously been a subordinate of the fiscal in charge of the case. The Court dismissed this claim, asserting that bias and partiality cannot be presumed and must be proven with evidence. In the absence of concrete proof, the Court upheld the presumption of regularity in Judge Calibo’s performance of his official duties. The Court added that “Mere imputation of bias and partiality against a judge is not enough, since bias and partiality can never be presumed.”
Finally, the Court addressed Decasa’s defense of alibi, which the lower courts had rejected. The Supreme Court reiterated that alibi is a weak defense, especially when the crime scene is easily accessible from the location where the accused claimed to be. In this case, the distance between Decasa’s house and the canal where the stabbing occurred was only 100 meters, making it entirely possible for him to commit the crime.
In conclusion, the Supreme Court affirmed Decasa’s conviction, modifying only the award of damages. While the Court sustained the civil indemnity of P50,000.00, it replaced the actual damages of P25,000.00 with temperate damages of the same amount, as the heirs failed to present sufficient documentary evidence of their expenses. This decision reinforces the principle that minor inconsistencies in a witness’s statements do not automatically negate their credibility, especially when their testimony is corroborated by other evidence and the trial court has had the opportunity to assess their demeanor.
FAQs
| What was the key issue in this case? | The key issue was whether inconsistencies between an eyewitness’s affidavit and their court testimony were significant enough to discredit their testimony and overturn a homicide conviction. The defense argued that these inconsistencies cast doubt on the witness’s credibility. |
| Why did the Supreme Court uphold the conviction despite the inconsistencies? | The Court ruled that affidavits are often incomplete and that minor inconsistencies do not automatically discredit a witness, especially when the core testimony is consistent with other evidence and the witness’s demeanor is credible. The Court also noted that the witness provided a reasonable explanation for the omission in their affidavit. |
| What is the difference between an affidavit and court testimony? | An affidavit is a written statement made under oath outside of court, while court testimony is given live, under oath, during a trial. Court testimony is generally considered more reliable because it allows for cross-examination and observation of the witness’s demeanor. |
| How did the Court address the argument that the judge did not hear all the evidence? | The Court stated that a judge can validly decide a case based on the records, transcripts, and evidence presented, even if they did not personally hear all the testimonies. In this case, the judge also conducted an ocular inspection of the crime scene. |
| What is the significance of motive in this case? | The Court ruled that motive is essential for conviction when there is doubt about the identity of the culprit. However, in this case, the eyewitness provided a direct account of the crime, making motive less critical. |
| What is the defense of alibi, and why did it fail in this case? | Alibi is a defense that claims the accused was somewhere else when the crime was committed. It failed in this case because the crime scene was easily accessible from the location where the accused claimed to be. |
| What is the meaning of temperate damages? | Temperate damages are awarded when actual damages are proven but the exact amount cannot be determined. In this case, temperate damages were awarded because the heirs could not provide sufficient documentary evidence of their expenses. |
| What was the main evidence used to convict Decasa? | The main evidence was the eyewitness testimony of Rogelio Boco, which was corroborated by the medical findings of Dr. Maria Nenita Tumanda. Boco’s testimony provided a direct account of the stabbing, while the medical findings confirmed the nature of the victim’s injuries. |
The Decasa v. Court of Appeals case illustrates the careful balance courts must strike when assessing witness credibility. While inconsistencies in statements can raise concerns, they do not automatically invalidate a witness’s account. The courts must consider the totality of the evidence, the witness’s demeanor, and the context of their testimony to determine the truth. The ruling underscores that a conviction can stand on reliable eyewitness testimony, even if initial statements contain minor omissions or variations.
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: NESTOR B. DECASA VS. COURT OF APPEALS and PEOPLE, G.R. NO. 172184, July 10, 2007