In *People v. Cariño*, the Supreme Court affirmed the conviction of Paquito Cariño for murder, emphasizing the importance of credible witness testimony and the evaluation of evidence by the trial court. The court reiterated that findings of trial courts on witness credibility are given great weight due to their unique opportunity to observe demeanor during testimony. This case underscores that a positive identification by a credible witness can be sufficient for conviction, even without direct evidence of motive, provided guilt is established beyond a reasonable doubt.

Eyewitness Account: Can a Witness’s Testimony Secure a Murder Conviction?

The case revolves around the fatal stabbing of Rolly Dispo. Mario Dispo, a cousin of the victim, testified that he witnessed Paquito Cariño stabbing Rolly multiple times while Rolly was seemingly asleep on a bench. This testimony became the cornerstone of the prosecution’s case, leading to Paquito’s conviction by the trial court. The defense challenged the credibility of Mario’s testimony, pointing out his relationship to the victim and inconsistencies in his statements. However, the Supreme Court sided with the trial court’s assessment, highlighting the trial judge’s advantage in evaluating the demeanor and sincerity of the witness.

The Supreme Court gave significant weight to the trial court’s assessment of Mario Dispo’s credibility. The Court stated:

The findings of the trial court on the credibility of witnesses deserve great weight, given the clear advantage of a trial judge in the assessment of testimonial evidence. The trial court enjoys the unique opportunity to observe the witnesses first-hand and to note their demeanor, conduct and attitude under grueling examination.

This underscores a foundational principle in Philippine jurisprudence: the deference appellate courts give to trial courts in matters of witness credibility. The Court emphasized that Mario Dispo had a clear view of the crime scene, was merely fifteen meters away from the accused, and nothing impaired his ability to observe. Furthermore, the Court noted the absence of improper motive on Mario’s part, dismissing the argument that his relationship to the victim inherently biased his testimony. The Court held:

Mere relationship of a witness to the victim does not impair his credibility as to render his testimony unworthy of credence. Relationship does not automatically affect the veracity of testimonies made by witnesses for there is no legal provision that disqualifies relatives of the victim from testifying if they are competent.

This ruling clarifies that while relationships may be considered, they do not automatically discredit a witness’s testimony. The focus remains on the witness’s competence, truthfulness, and the consistency of their account. In evaluating the evidence, the concept of **corpus delicti** played a critical role. The defense argued the prosecution failed to present adequate proof of the crime committed, but the Court clarified the elements of corpus delicti:

In murder, the corpus delicti refers to the body, foundation or substance, upon which the crime has been committed, e.g., the corpse of a murdered man. Its elements are: (a) a certain result has been proven, i.e., a man was killed; and (b) some person is criminally responsible therefor. It does not refer to the autopsy report evidencing the nature of the wounds sustained by the victim nor the testimony of the physician who conducted the autopsy or medical examination.

The Court found that the death of Rolly Dispo and Paquito Cariño’s responsibility for the act were sufficiently proven, fulfilling the requirements of **corpus delicti**. Moreover, the testimony of Dr. Vicente Cacho Jr., who conducted the autopsy, corroborated Mario Dispo’s account, further solidifying the prosecution’s case.

Another critical factor in the Court’s decision was Paquito Cariño’s flight from the crime scene. The Court stated:

His flight from the place after the commission of the crime bolsters his culpability.

Flight is often considered circumstantial evidence of guilt, as it suggests a consciousness of wrongdoing. Paquito’s departure to Quezon province shortly after the incident, coupled with his implausible explanation, weakened his defense and supported the inference of guilt. Although the defense claimed that others were the real perpetrators, the Court dismissed this claim due to a lack of evidence and the establishment of a solid alibi for the accused individuals.

Finally, the Court addressed the issue of **motive**. While motive can be crucial in establishing guilt, the Court clarified that its absence is not fatal to the prosecution’s case when other evidence strongly points to the accused:

Notwithstanding the apparent lack of motive on his part to kill the victim, all other evidence point to accused-appellant as the perpetrator of the crime. Hence, motive is no longer necessary.

The presence of treachery (*alevosa*) was also a significant factor in qualifying the killing as murder. The Court determined that Paquito Cariño attacked Rolly Dispo while he was drunk, unconscious, and defenseless. This element of surprise and vulnerability demonstrated treachery, elevating the crime from homicide to murder. The Court modified the civil indemnity awarded, reducing it to P50,000.00 in line with prevailing jurisprudence, and added P50,000.00 as moral damages for the victim’s family. The absence of proof for funeral expenses precluded an award of actual damages.

FAQs

What was the key issue in this case?	The key issue was whether the testimony of a single eyewitness, Mario Dispo, was sufficient to convict Paquito Cariño of murder beyond a reasonable doubt. The court assessed the credibility and weight of the eyewitness account.
What is corpus delicti?	Corpus delicti refers to the body or foundation of a crime, establishing that a crime has occurred. In murder, it requires proof that a person was killed and that someone is criminally responsible.
Does relationship to the victim automatically disqualify a witness?	No, relationship to the victim does not automatically disqualify a witness. The witness’s testimony is evaluated based on credibility, competence, and consistency, not merely on their relation to the victim.
What is the significance of flight in a criminal case?	Flight from the crime scene can be considered circumstantial evidence of guilt. It suggests a consciousness of guilt and an attempt to evade prosecution.
Is motive essential for a murder conviction?	While motive can be helpful in establishing guilt, it is not essential for a murder conviction. If there is sufficient evidence identifying the accused as the perpetrator, motive is not required.
What is treachery (alevosa)?	Treachery is the employment of means, methods, or forms in the execution of a crime that tend directly and specially to ensure its execution, without risk to the offender arising from the defense which the offended party might make.
What damages are typically awarded in murder cases?	Damages typically awarded include civil indemnity for the death, moral damages for the victim’s family’s pain, and sometimes actual damages if proven. Civil indemnity is awarded without need of evidence or proof of damages.
Why did the Supreme Court defer to the trial court’s assessment of witness credibility?	The Supreme Court defers to the trial court because the trial judge has the unique opportunity to observe the demeanor, conduct, and attitude of witnesses firsthand during testimony, providing a better basis for assessing credibility.

The *People v. Cariño* case illustrates the critical role of witness testimony and judicial assessment in criminal convictions. It reinforces the principle that credible eyewitness accounts, when coupled with corroborating evidence, can establish guilt beyond a reasonable doubt, even in the absence of a clear motive. The decision serves as a reminder of the importance of thorough investigation and careful evaluation of evidence in the pursuit of justice.

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. Cariño, G.R. No. 146436, September 30, 2002