Case Digest (G.R. No. 103292)
Facts:
On 14 October 1988, The People of the Philippines charged Modesto Cabuang and Nardo Matabang with robbery with rape and homicide after Evelyn De Vera and her cousin Maria Victoria Parana were accosted at night in Barangay Buenlag I, Bayambang, Pangasinan; Evelyn hid and later identified the two men as among those who seized Maria Victoria, who was found the next morning raped, mutilated, and dead. At trial the Regional Trial Court convicted both accused and sentenced them to reclusion perpetua and ordered various damages and indemnity, prompting this appeal.
Issues:
- Was Evelyn De Vera’s identification of Modesto Cabuang and Nardo Matabang admissible and sufficient despite an earlier police blotter entry stating the assailants were “still unidentified”?
- Did the appellants’ pleas of alibi create reasonable doubt to overturn the convictions?
Ruling:
The Court affirmed the convictions of Modesto Cabuang and Nardo Matabang for robbery with rape and homicide and upheld the awards of damages, but increased the indemnity from P50,000.00 to P100,000.00; costs were imposed against the appellants. The Court found the identification reliable and the alibi defenses unproved and insufficient to raise reasonable doubt.
Ratio:
The Court held that a brief delay in a traumatized witness’s reporting did not destroy credibility, and entries in a police blotter were only prima facie and not conclusive against later sworn statements and in-court identification. The Court found the eyewitness testimony, the lineup identification, the proximity of the accused to the scene, the failure of alibis to be corroborated, and the corroborative forensic and circumstantial evidence formed an unbroken chain inconsistent with innocence and satisfying Rule 133, Section 2, Revised Rules of Court.
Doctrine:
- A delay of a few hours or days by a traumatized witness in identifying offenders does not, by itself, render the testimony incredible.
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