GR 160858; (February, 2006) (Digest)
G.R. No. 160858 February 28, 2006
ROLITO RABANAL, Petitioner, vs. PEOPLE OF THE PHILIPPINES and HON. COURT OF APPEALS, Respondents.
FACTS
Petitioner Rolito Rabanal was charged with homicide for the stabbing death of Felipe Sales. The prosecution’s case rested primarily on the eyewitness account of Dionisio Javier, who testified that he saw Rabanal, along with Salvador Impistan and Eloy Labatique, stab the victim inside a chapel. Javier claimed Rabanal initiated the attack by stabbing Sales in the right armpit. The defense presented an alibi, with Rabanal claiming he was at work and later at a wake, and another witness, Raymundo Buenaventura, testifying that Rabanal was not at the crime scene and that only Impistan and Labatique committed the stabbing. The Regional Trial Court convicted Rabanal of homicide, giving credence to Javier’s testimony, and the Court of Appeals affirmed the conviction.
ISSUE
Whether the Court of Appeals erred in affirming petitioner’s conviction despite alleged inconsistencies between the lone eyewitness’s testimony and the physical evidence.
RULING
The Supreme Court denied the petition and affirmed the conviction. The Court held that the alleged inconsistency—Javier’s testimony that Rabanal stabbed the victim in the right armpit, while the autopsy report showed no wound in that specific location—did not discredit Javier’s entire account. The medico-legal expert testified the victim sustained 26 stab wounds, and the absence of a wound in one described location does not negate the occurrence of the stabbing or the witness’s identification of the assailant. The Court emphasized that testimonial evidence prevails over physical evidence when the former is credible and convincing. Javier’s positive identification of Rabanal as a participant was clear and consistent on material points. The defense of alibi was weak and could not prevail over this positive identification. The trial court’s assessment of witness credibility is entitled to great weight, and no compelling reason was shown to overturn its findings. The conviction for homicide was thus sustained, with the penalty and civil indemnity affirmed.