GR 145209; (June, 2006) (Digest)
G.R. No. 145209 ; June 8, 2006
LYDIO ALVERO, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
Petitioner Lydio Alvero was charged with Homicide with Double Physical Injuries and Damage to Properties Through Reckless Imprudence. The information alleged that on September 9, 1991, in Banga, South Cotabato, Alvero, while driving a passenger jeepney, recklessly bumped a motorcycle, resulting in the death of a passenger and injuries to others. He pleaded not guilty. The prosecution presented evidence, including the testimony of investigating officer Luvimin Servañez, eyewitness Alex Bacolor, and victim Nestor Villa. Their testimonies consistently placed the motorcycle on its proper lane and described the jeepney bumping the motorcycle’s rear portion.
The defense presented Armado Fanela and Alvero himself. Alvero testified that he was driving within the speed limit and that the motorcycle suddenly swerved into his path, making the collision unavoidable. On cross-examination, however, he admitted that he did not immediately report the accident to the police but was later fetched from his house. The trial court convicted Alvero, a decision affirmed by the Court of Appeals.
ISSUE
Whether the Court of Appeals erred in affirming Alvero’s conviction based on the evidence presented.
RULING
The Supreme Court denied the petition and affirmed the conviction. The Court emphasized that factual findings of the trial court, especially when affirmed by the Court of Appeals, are generally binding. Alvero’s petition failed to show that the case fell under any recognized exception to this rule warranting a re-evaluation of the evidence.
The legal logic centers on the credibility of the prosecution’s evidence against Alvero’s defense. The consistent testimonies of the prosecution witnesses established that Alvero was driving recklessly by following the motorcycle too closely and bumping it from behind while it was on its correct lane. Crucially, the Court gave weight to Alvero’s own testimony and admissions during cross-examination. By taking the witness stand, he waived his right against self-incrimination, and his statements became admissible against him. His admission that he did not immediately report the accident contradicted his claim of innocence and was construed as an indication of guilt. His testimony, instead of exculpating him, ultimately corroborated the prosecution’s narrative of reckless driving. Thus, the evidence sufficiently proved his guilt beyond reasonable doubt.