Case Summary (G.R. No. 209342)
Eyewitness Identification and Its Frailties
Both Cruz and Perez made positive in-court identifications of Nuaez nearly eight years after the crime, despite earlier testimony (Cruz in 2002) admitting inability to recall the fourth robber’s features. The lapse of time, stress of the hold-up, absence of prior description, procedural suggestiveness (sole presentation of Nuaez post-arrest), and contradictory accounts between the two witnesses all undermine reliability.
Governing Eyewitness-Identification Standards
Under the 1987 Constitution and Supreme Court precedents, conviction cannot rest solely on uncorroborated eyewitness testimony. Philippine jurisprudence applies the “totality of circumstances” test (People v. Teehankee, Jr.), considering: (1) witness’s opportunity to observe; (2) degree of attention; (3) accuracy of prior description; (4) level of certainty at confrontation; (5) retention interval; and (6) suggestiveness of identification procedure. Complementary “danger signals” (People v. Pineda) further alert courts to weaknesses such as initial inability to identify, long delays, multiple perpetrators, and suggestive line-ups or show-ups.
Application of Totality Test and Danger Signals
- Opportunity and Attention: Stress and flight response limited both witnesses’ ability to observe details.
- Prior Description and Certainty: No contemporaneous description of the fourth robber; original denial of recognition conflicts with later certainty.
- Retention Interval: Eight-plus years elapsed before identification, far exceeding intervals deemed acceptable.
- Suggestiveness: Witnesses saw only Nuaez presented alone post-arrest, practically compelling identification.
- Inconsistencies: Cruz and Perez offered divergent accounts of how many robbers participated and who fired shots, indicating unreliability.
- Danger Signals: Multiple criteria from Pineda are met, including initial nonidentif
Case Syllabus (G.R. No. 209342)
Facts of the Crime
- On or about June 22, 2000, at the Caltex gasoline station in Binangonan, Rizal, four armed men conspired to rob and kill.
- The assailants demanded ₱5,000.00 and cans of oil from Felix V. Regencia, Alexander C. Diaz, and Byron G. Dimatulac.
- A struggle ensued when Regencia resisted; Diaz shouted; two men (identified as Marciales and NuAez) ran in and opened fire, killing all three victims.
Initial Prosecution and Conviction of Co-accused
- George Marciales and Orly Nabia were arrested, tried, and in December 2005 convicted of robbery with homicide; both received death sentences.
- Paul Pobre and an alias “Jun” remained at large; their cases were archived pending apprehension.
Arrest and Identity Controversy of Accused-Appellant
- On July 2, 2006, Crisente Pepaao NuAez was arrested by PNP as the alleged “Paul Pobre.”
- NuAez denied being Pobre and moved to dismiss; prosecution witnesses nonetheless identified him, leading to amendment of the Information.
Trial Proceedings Against NuAez
- Prosecution adopted prior trial evidence and recalled Ronalyn Cruz and Relen Perez to positively identify NuAez.
- Cruz and Perez described seeing him point a gun at Diaz (or Regencia), enter the office during the holdup, and fire shots.
- NuAez testified to a mistaken apprehension, recounted being blindfolded, beaten, and offered an alibi placing him at his aunt’s fish store and home.
Regional Trial Court Decision
- On February 24, 2010, RTC found NuAez guilty beyond reasonable doubt of robbery with homicide under Article 294(1) RPC.
- RTC applied statutory elements, credited witness certainty, and rejected the defense alibi as “weak.”
- Sentenced to reclusion perpetua; ordered to pay funeral expenses, indemnities, exemplary and moral damages, and unearned income to victims’ heirs; “Jun” case archived.
Court of Appeals Review
- On June 26, 2013, CA dismissed NuAez’s appeal for lack of merit, affirmed conviction, but reduced moral damages to ₱75,000.00 and exemplary damages to ₱30,000.00 per heir.
- CA decision elevated to the Supreme Court.
Issue on Appeal
- Whether the prosecution proved beyond reasonable doubt that Crisente NuAez is the same individual earlier identified as Paul Pobre who conspired in the robbery with homicide.
Eyewitness Identification: Scientific and Jurisprudential Context
- Human memory is selective, reconstructive, and degrades over time; confidence does not guarantee accuracy.
- U.S. Supreme Court rulings (Wade, Gilbert, Stovall, Biggers, Manson) require reliability under totality of circumstances, not per se admissibility.
- U.K. Code of Practice prescribes unbiased line-ups, witness instructions, and pre-identification descriptions.
- Philippine test (People v. Teehankee, Jr.) embraces six factors: witness’s opportunity to view, degree of attention, accuracy of prior description, level of certainty, time lapse, and suggestiveness of procedure.
Deficiencies in Prosecution’s Identification Evidence
- Cruz initially stated she could not recall or describe the fourth robber; only years later identified NuAez.
- Perez’s account conflicted with Cruz’s regarding the sequence of entry, number of assailants, and who fired shots.
- Nearly eight to nine years elapsed between the crime and the in-court identification.
- NuAez’s presentation for identificat