G.R. No. 247651 - People vs. Libunao y Mariano

The case involves an appeal from the decision of the Court of Appeals (CA) granted in CA-G.R.CR No. 40234, which had affirmed the conviction and sentence rendered by the Regional Trial Court (RTC) of Quezon City, Branch 100.
Appellant Mark Ian Libunao y Mariano was charged with murder in an information dated January 5, 2015. The charging document accused him of having committed the crime on December 19, 2014, in Quezon City by using an Isuzu Sportivo Wagon (Plate No. AAB-4197) to drag and strike the victim, Sonny Dela Cruz Acosta, an MMDA Traffic Enforcer.

On December 19, 2014, MMDA enforcers, including Liberty Tongco and Lourdes S. Liton, were on duty at EDSA near Farmers Market, Cubao when events unfolded.
Traffic Enforcer Acosta apprehended the maroon-colored vehicle for a traffic violation.
Witnesses reported that after the initial confrontation, the vehicle sped away. In the process, Acosta was dragged and sustained head injuries that eventually rendered him unconscious.
The victim’s condition deteriorated, and he died on December 23, 2014, from injuries sustained in the incident.

Liberty Tongco testified that she observed Acosta apprehending the vehicle, noted the vehicle’s movement, and described the aftermath where Acosta was found injured near a gutter, with the car speeding off.
Lourdes S. Liton, another MMDA enforcer, testified that upon noticing a sudden noise and falling body near the pavement, she saw Acosta lying with head injuries while the vehicle was fleeing, though she only saw the back of the vehicle due to its tinted windows.
Rommel P. Montipio, a barker for public buses, testified that he was in close proximity (about five steps away) to the speeding vehicle. He observed Acosta’s interaction with the driver of the Sportivo and later identified the appellant as the driver in both a police line-up and in court.

Additional evidence, including testimonies by Rechille Acosta (the victim’s wife), PCI Erlito Trinidad Renegin (Traffic Enforcement Unit Chief), and Dr. Maria Cecilia F. Lim (forensic pathologist), was introduced.
Rechille testified about the familial and financial impact of her husband’s death, including details of hospital and funeral expenses.
PCI Renegin presented investigative findings, including the verification that the vehicle belonged to Dante Borguete and that the appellant admitted to being the authorized driver despite an expired driver’s license.
Dr. Lim detailed the autopsy findings, attesting to the fatal craniocerebral injuries that caused the victim’s death.

Upon arraignment, appellant pleaded not guilty.
The RTC granted a Motion for Bail on June 26, 2015, noting that the identification issue had been sufficiently resolved by witness Montipio’s declarations.

While the prosecution’s case rested heavily on the identification of appellant as the driver by witness Montipio, discrepancies arose during cross-examination.
Testimony by Montipio revealed the limitations of his identification: his position was somewhat oblique; he was distracted by his duty as a barker; the vehicle’s tinted windows made it difficult to see the driver; and there was a seven-day gap between the incident and his formal identification in a lineup.

On February 16, 2017, the RTC convicted appellant of homicide, imposing an indeterminate prison term (minimum of seven years and a maximum of fifteen years) along with civil liabilities to the victim’s heirs.
Appellant’s subsequent motions, including his motion for reconsideration and claims of illegal arrest, were denied at both RTC and CA levels.
The CA, in its decision dated May 9, 2018, and the subsequent Resolution dated January 11, 2019, upheld the RTC’s judgment and denied the appellant’s motion for reconsideration while granting the request for the release of the vehicle registered under Dante Borguete.

Appellant filed an appeal with the Supreme Court challenging the evidentiary basis of his identification and the credibility of witness Montipio’s testimony.
The Supreme Court observed discrepancies in Montipio’s testimony, particularly regarding his proximity to a dark, tinted vehicle and the divided attention due to his job as a barker.
Citing legal precedents and the principle that any doubt in the identity of the offender favors the accused, the Supreme Court reversed the CA decisions and set aside the RTC conviction, ordering the immediate release of the appellant.

Was the identification of the appellant by witness Montipio reliable given his proximity, attention, and the conditions under which the observation was made (i.e., the vehicle’s tinted windows and his duty as a barker)?
Could the short window of observation and delayed formal identification (seven days later in a police line-up) compromise the credibility of the identification?

Did the prosecution present ample proof to establish beyond reasonable doubt that the appellant was the driver who committed the homicide?
Were all elements of the crime of homicide satisfactorily established by the presented testimonies and corroborating evidence?

Did the trial and subsequent proceedings adequately respect and consider the appellant’s constitutional presumption of innocence, particularly in light of the identification errors?
Was the appellant’s claim of illegal arrest (and related procedural complaints) properly addressed considering his voluntary participation in the trial?

How do setbacks in the witness’s observation—specifically due to distance, obstructed view by tinted windows, and divided attention—influence the case’s outcome?
Should the inherent uncertainties in eyewitness identification weigh in favor of acquittal given the constitutional presumption of innocence?