People vs. Paredes
G.R. No. 115217 (November 21, 1996)
Facts:
On April 12, 1989, at around 5:00 PM, Amelito Banug and Evangelio Asis Jr. were walking home in Kauswagan, Cabacungan, Barobo, Surigao del Sur, when they encountered the Paredes brothers, Danny and Santos Jr. (alias Titing). Danny was armed with a long firearm, while Santos Jr. held a knife. Sensing danger, Amelito and Evangelio attempted to flee but heard gunfire shortly after. Amelito turned back to see Danny shooting Evangelio, who fell to the ground. Santos Jr. then stabbed the already downed Evangelio. Amelito rushed to inform Evangelio's parents and returned to the scene with them, where they found Evangelio dead, having sustained four gunshot wounds and two stab wounds.
On January 9, 1991, the Paredes brothers were charged with murder in the Regional Trial Court of Lianga, Surigao del Sur. Danny claimed an alibi, stating he had been shot by Evangelio's father on April 8, 1989, and was hospitalized until April 20, 1989. His alibi was supported by a medical certificate and the testimony of a witness who claimed to have been in the same hospital room. The trial court accepted Danny's alibi but found Santos Jr. guilty based on Amelito's positive identification.
Santos Jr. appealed his conviction, arguing that he was not present at the crime scene and that he was entitled to a privileged mitigating circumstance due to his minority, as he was only 15 years old at the time of the crime.
Legal Issues:
- Whether Santos Paredes Jr. was present at the scene of the crime and whether the evidence against him was credible.
- Whether Santos Jr. was entitled to the privileged mitigating circumstance of minority under the Revised Penal Code.
Arguments:
For Santos Paredes Jr.:
- He argued that the testimony of Amelito was not credible, especially since Danny was acquitted based on the same testimony.
- He claimed that he was only 15 years old at the time of the crime, which should entitle him to a privileged mitigating circumstance.
For the Prosecution:
- The prosecution maintained that Amelito's identification of Santos Jr. as one of the assailants was credible and should not be disregarded simply because Danny was acquitted.
- The prosecution argued that Santos Jr.'s alibi was weak and did not establish physical impossibility of being at the crime scene.
Court's Decision and Legal Reasoning:
The court upheld the trial court's finding of guilt against Santos Paredes Jr. but modified the sentence. The court reasoned that the credibility of witnesses is primarily determined by the trial court, which had the opportunity to observe their demeanor. The court noted that the trial court's acceptance of Amelito's testimony against Santos Jr. was valid, despite the acquittal of Danny, as the credibility of a witness can vary based on the circumstances of each case.
Regarding the alibi, the court emphasized that for an alibi to be a valid defense, it must be established that it was physically impossible for the accused to be at the crime scene. Santos Jr. failed to demonstrate such impossibility, as he and Danny testified that the distance could be covered in about three hours.
However, the court found merit in Santos Jr.'s argument regarding his age. It clarified that under Article 13, paragraph (2) of the Revised Penal Code, being under 18 years of age is a mitigating circumstance. The court noted that the trial court erred in considering Santos Jr.'s age at the time of trial instead of at the time of the offense. Consequently, the court imposed a lesser penalty, taking into account the mitigating circumstance of minority.
Significant Legal Principles or Doctrines Established:
- The credibility of witnesses is primarily determined by the trial court, which is in a better position to assess their demeanor and reliability.
- The principle of "falsus in uno, falsus in omnibus" (false in one thing, false in everything) is not an absolute rule and can be applied selectively based on the credibility of the witness.
- The age of the accused at the time of the offense is crucial in determining eligibility for mitigating circumstances under the Revised Penal Code.