People vs. Lapura

G.R. No. 94494 (March 15, 1996)

Facts:

On February 19, 1988, Petronilo Lim, a special agent of the Criminal Investigation Service, was shot multiple times while driving his car in Manila. Eyewitness Edgardo Samson, who was nearby, observed two assailants: one positioned at the front right side of the car and another at the left side. After the shooting, Lim exited his vehicle and attempted to return fire with an armalite rifle but was ultimately overpowered. He sustained fatal injuries from three gunshot wounds, which were later confirmed by an autopsy conducted by Dr. Marcial CeAido.

Dionisio Lapura y Cajan, the accused, was arrested on February 25, 1988, five days after the incident. He was identified by Samson in a police line-up and subsequently charged with murder. The information filed against him alleged that he, along with others, conspired to kill Lim with evident premeditation and treachery.

During the trial, Lapura presented an alibi, claiming he was asleep at his sister's house at the time of the shooting. His sister corroborated this, stating that she left the house at 6:30 a.m. and returned shortly after, finding him still asleep. The prosecution, however, relied heavily on the eyewitness testimony of Samson, who identified Lapura as the shooter.

The trial court ultimately convicted Lapura of murder, imposing the penalty of reclusion perpetua, while reserving the right for the victim's heirs to file a separate civil suit for indemnification.

Legal Issues:

1. Whether the information filed against Lapura was valid despite claims of procedural defects regarding the authority of the city fiscal.
2. Whether the eyewitness identification of Lapura was credible and sufficient to support a conviction for murder.
3. Whether Lapura's constitutional rights were violated during the police line-up and subsequent investigation.

Arguments:

Prosecution:

• The prosecution argued that the information was valid, supported by the certification of the investigating fiscal, which attested to the proper filing of the case.
• Eyewitness Edgardo Samson's testimony was credible and consistent, providing a clear identification of Lapura as the shooter.
• The prosecution maintained that the circumstances of the crime indicated treachery, as the attack was sudden and without warning.

Defense:

• The defense contended that the information was fatally flawed due to the lack of written authority from the city fiscal and alleged deficiencies in the certification.
• The defense argued that Samson's testimony contained inconsistencies and contradictions, undermining its reliability.
• Lapura claimed that he was denied his right to counsel during the police line-up, which should render the identification inadmissible.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, holding that the information was valid despite the defense's claims. The presumption of regularity in the performance of official functions was upheld, and the court found no compelling evidence to contradict the fiscal's certification.

Regarding the eyewitness identification, the court found Samson's testimony credible and consistent, noting that he had identified Lapura in both a police line-up and in court. The court emphasized that the absence of motive does not negate the strength of the identification when it is clear and convincing.

On the issue of constitutional rights, the court ruled that Lapura had waived any irregularities related to his arrest and the police line-up by entering a plea of not guilty and participating in the trial. The court also noted that the presence of Lapura's counsel during the line-up indicated that he had legal representation.

The court concluded that treachery was present in the commission of the crime, justifying the imposition of the penalty of reclusion perpetua.

Significant Legal Principles Established:

• The presumption of regularity in the performance of official duties applies to the filing of information by the city fiscal.
• Eyewitness identification can be sufficient for conviction, even in the absence of motive, provided it is credible and consistent.
• A defendant waives certain rights, including the right to challenge procedural irregularities, by actively participating in the trial process.