G.R. No. 138553 - Rivera vs. People

Case Summary (G.R. No. 138553)

Petitioner and Respondent

Petitioner: Enrique aTotoya Rivera
Respondent: People of the Philippines

Key Dates

Incident: March 20, 1993
Filing of Information: May 6, 1993
RTC Decision: April 22, 1994
CA Decision: October 16, 1998; CA Resolution on Reconsideration: April 5, 1999
SC Decision: June 30, 2005

Applicable Law

1987 Philippine Constitution
Revised Penal Code, Article 148 (Direct Assault)
La Trinidad Municipal Ordinance No. I-91 (prohibiting loading/unloading of chicken manure near highway)

Procedural History

An information for direct assault was filed against Rivera in the RTC of La Trinidad. After trial, the RTC convicted him of direct assault on April 22, 1994, sentencing him to 4 months & 1 day to 1 year, 1 month & 11 days and a ₱500 fine. His motion for reconsideration was denied. On appeal (CA-G.R. CR No. 17284), the Court of Appeals affirmed the conviction (Oct. 16, 1998) and denied reconsideration (Apr. 5, 1999). The Supreme Court denied Rivera’s petition for review on certiorari, affirming in toto.

Prosecution’s Version of Facts

Lt. Leygo and SPO1 Basquial enforced Ordinance I-91 by stopping a truck unloading chicken manure along the Halsema Highway. The driver complied and the police escorted the truck away.
Later, two other policemen stopped the same truck; Leygo felt slighted and summoned reinforcements.
Rivera arrived, ordered the driver to defy the police, and followed in his vehicle. Leygo’s group intercepted the truck again at Dengsi, Tomay.
Upon confrontation, Rivera hurled insults, removed his jacket, assumed a fighting stance and refused arrest.
After a warning, Rivera punched Leygo in the face; a brief struggle ensued before police subdued and arrested Rivera.
Both the victim and Rivera underwent medico-legal examination, showing contusions and lacerations consistent with the altercation.

Defense’s Version of Facts

Rivera directed the truck to Acop, Tublay, after an initial prohibition on unloading in La Trinidad.
Believing policemen at Cruz were extorting money, he told the driver to proceed.
Upon being stopped at Dengsi, Rivera claimed Leygo grabbed his jacket, threatened him, smelled of liquor, and struck him first.
Rivera raised his hands to show he carried no weapon and only minor injuries resulted when Leygo slapped him. He did not throw any punch.

Trial Court Findings

Credited Lt. Leygo’s clear, consistent testimony despite minor lapses in recall or volume.
Found defense version improbable: officer unlikely to self-inflict injury or collude with colleagues to fabricate assault.
Noted Rivera’s aggressive demeanour and defiance on the witness stand.
Concluded Rivera committed direct assault and imposed the prescribed penalty and fine.

Court of Appeals Ruling

The Court of Appeals affirmed the RTC decision in full, adopting its factual findings and legal conclusions.

Issue on Appeal

Whether the CA erred in affirming the conviction, specifically regarding witness credibility, sufficiency of evidence, performance of official duties, absence of medical testimony, and assessment of demeanor.

Direct Assault Under Article 148 RPC

Defined as an attack or resistance against a person in authority while performing official duties.
Aggravated when committed with a weapon, by a public officer, or by laying hands on a person in authority.
Rivera’s punch on Lt. Leygo plainly falls within direct assault against an on-duty officer.

Assessment of Witness Credibility

Minor lapses or inability to recall every detail do not undermine credibility; they may indicate spontaneity, not rehearsal.
Trial court’s firsthand observations of testimony carry great weight; Supreme Court defers absent arbitrariness.
Even a single credible witness suffices for conviction if testimony is straightforward and categorical.

Sufficiency of Evidence

Consistent accounts that Rivera alone engaged Leygo.
No motive for Leygo or co-policemen to fabricate the incident.
Corroborative medical certificate supported the occurrence of an assault but was not indispensable.

Performance of Official Duties

Leygo was in full uniform, on patrol, enforcing a valid munic