In People v. Enriquez, the Supreme Court affirmed the conviction of Tomas Enriquez for murder, emphasizing the importance of witness credibility in establishing guilt beyond reasonable doubt. The Court acknowledged minor inconsistencies in witness testimonies but upheld the trial court’s assessment, underscoring that these discrepancies did not undermine the witnesses’ overall truthfulness. This case serves as a reminder of how crucial eyewitness accounts are, even when there are some differences in their recounting of events, and reinforces the principle that the essence of the testimony, when consistent, can still lead to a just outcome.

Echoes of the Past: Can Justice Prevail Despite Years of Silence?

The case revolves around the murder of Jessie Conlu, which occurred on October 13, 1979, in Iloilo City. Tomas Enriquez was identified as the assailant by two eyewitnesses, Rene de la Peña and Romeo Ladrillo. However, the trial was significantly delayed, and the witnesses only came forward years after the incident. The primary legal question was whether the testimonies of Rene and Romeo were credible enough to convict Enriquez, given the inconsistencies in their accounts and the long delay in reporting the crime.

The prosecution presented Dr. Tito Doromal, the medico-legal officer, who testified about the autopsy he conducted on Jessie Conlu, confirming that the cause of death was a stab wound inflicted by a sharp, pointed instrument. Rene de la Peña and Romeo Ladrillo both testified that they saw Enriquez stab Conlu. Rene, a stevedore at the time, recounted that Enriquez had even solicited his help to kill Jessie prior to the incident, which he refused. Romeo, working as a foreman, also corroborated Rene’s account, adding that he had known Enriquez under the alias Rodolfo Enriquez.

The defense presented Wilfredo Altamia, a member of a musical band, who testified that Enriquez was with him and the band in Maayon, Capiz, on the day the crime was committed, providing an alibi. Christian de la Peña, Rene’s brother, also testified, stating that he was unaware of any such incident. Enriquez himself denied any involvement, claiming he was in Maayon, Capiz, with his band on the day of the murder and suggesting that the charges were politically motivated.

The trial court gave significant weight to the eyewitness accounts, noting that both Rene and Romeo positively identified Enriquez as the assailant. The court also found that the inconsistencies in their testimonies were minor and did not detract from their credibility. In its decision, the trial court stated that the identity of the accused as the person who stabbed and killed the victim, Jessie Conlu, has been properly established by eye-witnesses Rene de la Peña and Romeo Ladrillo. Positive identification, especially when the witnesses are familiar with the accused, is a cornerstone of criminal prosecution.

The Supreme Court upheld the trial court’s assessment of the witnesses’ credibility. The Court acknowledged that minor inconsistencies existed but emphasized that these did not undermine the overall truthfulness of their testimonies. According to the Court, minor inconsistencies do not affect the credibility of a witness; on the contrary, they may be considered badges of veracity or manifestations of truthfulness on material points and they may even heighten the credibility of the witness. This legal principle recognizes that human memory is fallible, and minor discrepancies can be expected in recounting past events.

Addressing the defense’s alibi, the Court reiterated that alibi is the weakest of all defenses for it is easy to fabricate and difficult to prove; it can not prevail over the positive identification of the accused by the witnesses. The prosecution’s positive identification of Enriquez, coupled with the lack of ill motive on the part of the witnesses, outweighed the defense’s alibi.

However, the Supreme Court modified the trial court’s decision regarding the penalty. The trial court had imposed the death penalty, but the Supreme Court reduced it to reclusion perpetua. The Court clarified that the crime was committed in 1979, before the enactment of Republic Act No. 7659, which restored the death penalty. Applying the death penalty retroactively would violate the constitutional proscription against ex post facto laws, which are laws that retroactively punish actions that were legal when committed or increase the punishment for a crime after it has been committed. The accused is entitled to the mitigation of penalty under Article 22 of the Revised Penal Code, which provides that penal laws shall have retroactive effect insofar as they favor the person guilty of a felony.

The Court also addressed Enriquez’s claim that his right to a speedy trial was violated. The Court ruled that the right to speedy trial is violated only where there is an unreasonable, vexatious and oppressive delay without the participation or fault of the accused, or when unjustified postponements are sought which prolong the trial for unreasonable length of time. The Supreme Court found that Enriquez himself contributed to the delay by initially evading arrest and later challenging the validity of his arrest through a petition for habeas corpus. Therefore, the delay could not be attributed to the prosecution, and his right to a speedy trial was not violated.

Furthermore, the Supreme Court affirmed the trial court’s finding that the crime was committed with treachery, qualifying the crime as murder. There is treachery when the offender commits any of the crime against the person, employing means, methods, or forms in the execution thereof which tend directly to insure its execution, without risk to himself arising from the defense which the offended party might make. This element was proven by the sudden and unexpected nature of the attack, where Enriquez approached the unarmed victim and stabbed him without warning, ensuring the execution of the crime without risk to himself.

The Court, however, did not find sufficient evidence to support the aggravating circumstance of evident premeditation. While Enriquez had expressed his intention to kill Jessie Conlu to Rene and Romeo, the prosecution failed to present convincing evidence of how Enriquez planned and prepared to execute the crime. Therefore, evident premeditation was not considered in determining the penalty.

FAQs

What was the key issue in this case?	The primary legal issue was whether the testimonies of the prosecution witnesses, Rene de la Peña and Romeo Ladrillo, were credible enough to convict Tomas Enriquez of murder, given inconsistencies in their accounts and a significant delay in reporting the crime. The court had to determine if these inconsistencies undermined their credibility and whether the delay affected the fairness of the trial.
Why did the witnesses come forward so late after the incident?	The witnesses came forward years later due to a combination of factors, including a sense of civic duty and prompting from others. They had initially hesitated to get involved due to fear and reluctance to engage in criminal prosecutions against people in their community.
How did the Court address the inconsistencies in the witness testimonies?	The Court acknowledged the minor inconsistencies but emphasized that they did not detract from the overall credibility of the witnesses. The Court noted that inconsistencies on minor matters are often considered badges of veracity rather than indicators of falsehood.
What was the defense’s argument, and why did it fail?	The defense argued that Enriquez was in Maayon, Capiz, with his band on the day of the murder, providing an alibi. This defense failed because the positive identification of Enriquez by the prosecution witnesses outweighed the alibi, which is considered the weakest form of defense.
Why was the death penalty reduced to reclusion perpetua?	The death penalty was reduced because the crime was committed in 1979, before the enactment of Republic Act No. 7659, which restored the death penalty. Applying the death penalty retroactively would violate the constitutional proscription against ex post facto laws.
Did the Supreme Court find that Enriquez’s right to a speedy trial was violated?	No, the Court found that Enriquez’s right to a speedy trial was not violated. The delays were, in part, due to Enriquez evading arrest and later challenging his arrest through a petition for habeas corpus, which contributed to the delay.
What role did treachery play in the Supreme Court’s decision?	The Supreme Court affirmed the trial court’s finding that the killing was committed with treachery, which qualified the crime as murder. The sudden and unexpected nature of the attack, coupled with the concealment of the weapon, demonstrated that Enriquez consciously employed a means to ensure the consummation of his objective without risk to himself.
Why was evident premeditation not considered an aggravating circumstance?	While Enriquez had expressed his intention to kill Jessie Conlu, the prosecution failed to present convincing evidence of how Enriquez planned and prepared to execute the crime. Without evidence of planning and preparation, evident premeditation could not be established as an aggravating circumstance.

People v. Enriquez underscores the judiciary’s commitment to upholding justice even in cases with delayed proceedings and minor testimonial inconsistencies. The decision emphasizes the importance of thorough investigation, credible witness accounts, and adherence to constitutional rights. The Supreme Court’s careful consideration of the evidence and legal principles ensures a just outcome, reinforcing the integrity of the legal system.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People v. Enriquez, G.R. No. 138264, April 20, 2001