GR 211642; (March, 2016) (Digest)
G.R. No. 211642 . March 09, 2016.
NELSON TEÑIDO Y SILVESTRE, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.
FACTS
Petitioner Nelson Teñido was charged with Robbery for breaking into the house of Lolita Enriquez in Manila on June 22, 1988, and stealing cash and valuables. The prosecution’s case primarily rested on the eyewitness account of Aurora Guinto, a neighbor whose house was directly opposite and five meters away from the crime scene. Guinto testified that at around 3:30 a.m., while opening her windows, she saw Teñido and another man attempt entry into a nearby house before successfully breaking into Enriquez’s residence by destroying a screen door. She recognized Teñido due to sufficient lighting and because she had known him since 1976 as a frequent loiterer in the neighborhood. The property owner, Enriquez, corroborated the loss of the items.
Teñido denied involvement, claiming he was at home with his parents at the time. He challenged Guinto’s credibility, pointing out her failure to immediately report the incident—she only came forward two months later—and alleged inconsistencies in her testimony regarding specific details like the perpetrators’ clothing and the exact sequence of their entry and exit.
ISSUE
Whether the Court of Appeals erred in affirming Teñido’s conviction for Robbery based on the eyewitness identification.
RULING
The Supreme Court denied the petition and affirmed the conviction. The Court emphasized that factual findings of the trial court, especially on witness credibility, are accorded great weight and respect on appeal. Guinto’s positive identification of Teñido was deemed credible and sufficient to establish guilt beyond reasonable doubt. Her familiarity with Teñido, the short distance from the crime scene, and the well-lighted premises provided an adequate basis for her recognition.
The Court rejected the attack on Guinto’s credibility. Her delayed reporting was satisfactorily explained by her fear and nervousness, and the alleged gaps in her testimony pertained to immaterial details that did not undermine the core fact of her identification. Denial and alibi, being weak defenses, could not prevail over the positive and categorical testimony of a credible eyewitness. All elements of Robbery under Article 299 of the Revised Penal Code were duly proven. The penalty was correctly modified by the CA in accordance with the Indeterminate Sentence Law.