GR 94134; (January, 1993) (Digest)
G.R. No. 94134 January 22, 1993
People of the Philippines, plaintiff-appellee, vs. Enrique Pariente y Giron, accused-appellant.
FACTS
On February 25, 1987, Carlos Garas, Jr. was fatally stabbed. The incident followed a prior altercation on October 31, 1986, where Garas had stabbed Enrique Pariente, resulting in serious physical injuries, which was settled without charges. More than one and a half years later, Enrique Pariente was charged with the murder of Carlos Garas, Jr. The Regional Trial Court of Quezon City, presided by Judge Jaime N. Salazar, found Pariente guilty and sentenced him to reclusion perpetua, plus damages. The prosecution’s case relied on the testimonies of three eyewitnesses: Florita Garas (the victim’s mother), Nelly Garas Rillorasa (the victim’s sister), and Rodrigo Sulayao (a store owner). They testified that they saw Pariente approach Garas, put an arm around him, and stab him in the back with a knife. The defense presented alibi, with Pariente claiming he was at home recuperating from his own stab wound at the time of the incident, a claim corroborated by his mother. The defense also challenged the credibility of the prosecution witnesses, particularly pointing out a contradiction in Florita Garas’s sworn statements and the delayed swearing of the witnesses’ statements.
ISSUE
Whether the evidence presented by the prosecution is sufficient to prove the guilt of the accused-appellant, Enrique Pariente, beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction with modifications. The Court held that despite flaws in the testimony of Florita Garas due to contradictions between her sworn statements, the consistent and detailed testimonies of the two other independent eyewitnesses, Nelly Rillorasa and Rodrigo Sulayao, sufficiently identified Pariente as the killer. Their testimonies were not impaired by the fact that their sworn statements, though dated February 25, 1987, were sworn to only on September 19, 1988, as they affirmed these statements on the stand without inconsistency. The defense of alibi could not prevail over the positive identification by credible witnesses. The delay in Pariente’s arrest did not equate to innocence. The appealed decision was AFFIRMED with the modification that the civil indemnity was increased to P50,000.00, and the awards for moral and exemplary damages were reduced to P20,000.00 each.