G.R. No. 73403 July 23, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDUARDO RABANG y CASTRO, defendant-appellant.

FACTS

The prosecution’s case rested primarily on the eyewitness account of Victor Boban. He testified that on October 6, 1984, at around 2:00 a.m. in the well-lit Asuncion Market in Tondo, Manila, he saw appellant Eduardo Rabang suddenly appear from behind the victim, Henry Cortes, and stab him at the nape with a fan knife. Boban, who was standing very close to the victim, clearly saw Rabang’s face. Immediately after, another man tried to stab Boban, prompting him to flee. Upon returning, he saw Rabang and others running away and found Cortes dead. Boban later identified Rabang in a police line-up at the Western Police District Homicide Section. The police investigation, initially hampered by witness fear, led to Rabang’s arrest in December 1984 based on an anonymous tip. The autopsy report confirmed the victim died from multiple stab wounds.
The defense presented alibi, claiming Rabang was elsewhere during the incident. On appeal, Rabang challenged the credibility of his identification, arguing it was “tailored-fit” and defective. He also contended the prosecution failed to overcome the constitutional presumption of innocence and questioned the legality of his warrantless arrest.

ISSUE

The core issues were: (1) whether the eyewitness identification of appellant was credible and sufficient to sustain a conviction, and (2) whether the warrantless arrest of appellant was lawful.

RULING

The Supreme Court affirmed the conviction. On the first issue, the Court upheld the trial court’s assessment of witness credibility, finding no reason to deviate from its conclusions. The witness, Victor Boban, had an unobstructed view of the attack under good lighting conditions and from a very short distance. His positive identification, made without any ill motive, was deemed credible and reliable. The Court emphasized that the lone testimony of a credible eyewitness is sufficient for a conviction. The claim of “tailored-fit” identification was rejected, as the identification procedure was not shown to be suggestive, and the witness had ample opportunity to observe the assailant during the crime itself.
Regarding the legality of the arrest, the Court ruled the warrantless arrest was valid under Rule 113, Section 5(b) of the 1985 Rules on Criminal Procedure, which allows an arrest when an offense has just been committed and the arresting officer has probable cause based on personal knowledge of facts indicating the person to be arrested committed it. Here, the police acted on an anonymous tip about the suspect’s whereabouts, coupled with the prior positive identification by an eyewitness. This provided the officers with personal knowledge of facts establishing probable cause. The delay between the crime and arrest was justified by witness fear and the difficulty in locating the appellant, a reported gang member. The Court found the arrest was made in good faith to prevent the appellant’s flight. Furthermore, any irregularity in the arrest was cured by the appellant’s voluntary submission to the court’s jurisdiction when he pleaded not guilty and participated in the trial. The penalty of reclusion perpetua and the awards for damages were sustained.