G.R. No. 139908 ; March 10, 2004
FERNANDO MANANGAN, petitioner, vs. COURT OF APPEALS (EIGHTH DIVISION) and the PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioner Fernando Manangan was charged with homicide for the stabbing death of Carlos Estacio on July 15, 1987, at the Olympian Bowling Lanes in Baguio City. The prosecution presented eyewitness Johnny It-itan, who testified that he saw Freddie Lacsamana strike Estacio on the head with a bottle, after which Manangan rushed in and attacked Estacio with a knife. Another eyewitness, Angelina Tobias, corroborated this account, testifying that she saw Lacsamana hold Estacio while Manangan stabbed him twice. The medico-legal report confirmed the victim died from a fatal stab wound.
The petitioner denied the accusation and presented a different version. He testified that he was at the bowling lanes with a friend, Arsenio Algaba, when he saw Lacsamana chasing and stabbing someone. He claimed he merely intervened to pacify Lacsamana and wrest the knife away from him, which he then handed to another person. He identified Lacsamana as the sole assailant.

ISSUE

The core issue is whether the prosecution proved the petitioner’s guilt for the crime of homicide beyond reasonable doubt, specifically by overcoming his defense of denial and his claim that another person was the perpetrator.

RULING

The Supreme Court affirmed the petitioner’s conviction. The Court found the testimonies of prosecution witnesses It-itan and Tobias to be clear, positive, and credible. Their consistent identification of Manangan as the one who stabbed the victim was given full weight. The Court emphasized that the trial court’s assessment of witness credibility is entitled to great respect, as it is in the best position to observe demeanor.
The legal logic centered on the weakness of the defense of denial when juxtaposed with strong positive identification. The petitioner’s claim that he merely disarmed Lacsamana was deemed inherently improbable and unsupported by credible evidence. The Court also addressed a minor inconsistency raised by the defense regarding whether Tobias was part of It-itan’s group that night. It ruled that It-itan’s failure to mention Tobias’s name in his list of companions did not discredit her testimony, as there was no evidence that the “Elena” he mentioned was not Angelina Tobias. This minor point did not affect the core consistency of their accounts on the identity of the assailant. Consequently, the prosecution successfully discharged its burden of proof, and the petitioner’s denial could not prevail over the positive identification by eyewitnesses.