Title
People vs. Yatco
Case
G.R. No. 138388
Decision Date
Mar 19, 2002
In the case of People v. Yatco, the Supreme Court affirms the conviction of Angelito Yatco for Robbery with Homicide, ruling that the credibility of eyewitnesses is valid and discrepancies in their statements are inconsequential, while also reducing the penalty to life imprisonment and ordering restitution and damages to the victim's family and San Miguel Corporation.
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Case Digest (G.R. No. 138388)

Facts:

  • Defendant: Angelito Yatco
  • Crime: Robbery with Homicide
  • Date: January 6, 1994
  • Place: Municipality of Sta. Rosa, Province of Laguna, Philippines
  • Brief account of events: Yatco tried to wrest something away from the victim, Enrico, a driver of a beer delivery truck. Yatco shot Enrico and took his sales collection amounting to P7,320.35.
  • Brief account of the case in the lower court: Yatco challenged the credibility of the eyewitnesses and the authority of the judge who rendered the decision.

Issue:

  • (Unlock)

Ruling:

  1. The trial court's findings on the credibility of witnesses are entitled to the highest degree of respect and will not be disturbed on appeal unless there is a clear showing of error.
  2. The discrepancies between the affidavits and testimonies of the witnesses do not necessarily discredit them.
  3. The judge who rendered the decision, although not the one who tried the case, had access to the complete records an...(Unlock)

Ratio:

  1. The trial court's findings on the credibility of witnesses are given great weight because they have the opportunity to observe the demeanor of the witnesses and assess their credibility firsthand.
  2. Discrepancies between affidavits and testimonies are common and do not automatically render the witnesses unreliable. Affidavits are often incomplete and inaccurate, and it is during the trial that the witnesses are given the opportunity to clarify and provide more accurate details.
  3. The lapses in the statements of the eyewitnesses pertain to inconsequential details and do not affect the core of the case, which is the identification of the defendant as the perpetrator of the crime.
  4. The defense of alibi, raised by Yatco, is weak and cannot prevail over positive identification by the eyewitnesses.
  5. The judge who rendered the decision had access to the complete records of the case and conducted a thorough evaluation. The fact ...continue reading

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