Case Summary (G.R. No. 109775)
First Assignment – Identification and Alleged Delay
Appellant argued that witnesses only identified him five months later, when they executed affidavits on September 17, 1991. The Court held those affidavits merely formalized identifications made immediately after the crime. Testimonies of early reports to Beloy, CAFGU, and the police negate any fatal delay. Failure to present the police blotter did not undermine the core testimonial evidence.
Weight and Credibility of Witness Testimony
The trial court’s evaluation of witness demeanor, consistency, and conduct is entitled to the highest respect on appeal. No material inconsistencies or unsupported conclusions were found. Judicial notice was taken of the natural hesitance of witnesses to report crimes against neighbors.
Second Assignment – Admission of Wallet and Contents
Appellant contended that pointing out Malaki’s hidden wallet during custodial investigation violated his rights against self-incrimination. The Court distinguished testimonial compulsion from seizure of physical evidence: the right against self-incrimination protects only compelled communications, not the collection of objects. Thus, the wallet and its contents (residence certificate, ID, keys) are admissible physical evidence.
Applicability of Miranda-Type Rights
Article III, Section 12 of the Constitution mandates advisement and written waiver for custodial interrogations; Section 12(3) excludes only extrajudicial confessions or admissions obtained in violation. Non-testimonial physical evidence obtained during custodial investigation remains admissible if relevant and not otherwise excluded by law.
Third Assignment – Sufficiency of Circumstantial Evidence
Conviction by circumstantial evidence requires multiple proved facts forming an unbroken chain leading exclusively to the accused. Five such circumstances were established:
- Positive identification by Rondon and Batin of appellant with a blood-stained bolo at the scene.
- Fatal stab wounds described in the medico-legal report.
- Witness Ladica saw appellant retrieve the wallet from under a stone at the seashore.
- Appellant’s own admission that on August 6, 1991 he led policemen to where he hid the wallet.
- Appellant’s flight and d
Case Syllabus (G.R. No. 109775)
Procedural Background
- G.R. No. 109775, November 14, 1996, Third Division decision penned by Justice Francisco.
- Accused-appellant charged by information (dated November 28, 1991) with the special complex crime of robbery with homicide (RPC, Art. 294(1)).
- Trial court (RTC, Southern Leyte, Branch 26) convicted appellant and imposed reclusion perpetua; ordered indemnity of ₱50,000 to the heirs of the homicide victim, Onofre Malaki, without subsidiary imprisonment for insolvency; costs imposed.
- Appellant filed three assignments of error on appeal:
• Credibility of witness identification delayed by over five months.
• Alleged constitutional violation in admission of wallet and contents.
• Alleged failure of the prosecution to prove guilt beyond reasonable doubt.
Facts of the Case
- April 15, 1991, around 8:00 PM, Onofre Malaki attended his store while his houseboy, Edilberto Batin, cooked supper in the rear kitchen.
- Farmer Florencio Rondon arrived to purchase farm chemicals; his home lay 150 m from Malaki’s store.
- Batin, upon entering the store, saw appellant emerging with a blood-stained bolo; Malaki lay on the floor, bleeding profusely.
- Rondon, five meters away and lit by a pressure lamp, saw and positively identified appellant as he fled with the bolo.
- Batin sought help from Eutiquio Beloy (Malaki’s brother-in-law); they returned to find Malaki dead in a pool of blood, the drawer ransacked, and Malaki’s wallet missing.
Assignments of Error on Appeal
- I. Trial court erred in giving credence to allegedly unreliable identification testimony due to a five-month delay.
- II. Trial court erred in admitting the wallet and its contents despite purported constitutional violations during its recovery.
- III. Trial court erred in convicting appellant de