GR L 45088; (February, 1985) (Digest)
G.R. No. L-45088 February 28, 1985
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EUSTAQUIO MANALO y REBOLLOS, defendant-appellant.
FACTS
The accused, Eustaquio Manalo, was charged with murder for the killing of Victor Saavedra. The prosecution evidence established that on September 15, 1973, the victim, his wife Julia, and their children were evacuating their home. While Victor was crossing a creek ahead of his family, Julia and her son Bernardito heard a gunshot and saw Victor fall from his carabao. After a second shot, they hid and witnessed Manalo approach the fallen victim with a slung shotgun, turn the body face up, and take Victor’s firearm and ammunition before leaving. The victim sustained multiple fatal gunshot wounds. The defense presented a barangay official and a policeman who testified that Julia initially told investigators she did not see the shooter, contradicting her court testimony.
ISSUE
The core issue is whether the alleged inconsistencies in the testimonies of the prosecution witnesses are sufficient to cast reasonable doubt on the guilt of the accused.
RULING
The Supreme Court affirmed the conviction, modifying only the civil indemnity. The Court ruled that the alleged inconsistencies highlighted by the defense—such as whether Julia specified the gun was slung on Manalo’s shoulder in her sworn statement versus her court testimony, and her initial purported reluctance to name the killer—pertain to trivial details that do not undermine the core veracity of her eyewitness account. The Court emphasized that minor discrepancies are common and may even indicate truthfulness, as rehearsed testimonies are often perfectly consistent. Furthermore, the Court held that proof of motive is not indispensable for conviction where, as here, there is positive identification of the accused by credible eyewitnesses. The friendly relationship between the accused and the victim prior to the incident does not negate guilt, as criminal intent can be concealed. The trial court’s assessment of witness credibility is accorded great respect, and no compelling reason was found to overturn its findings. The penalty of reclusion perpetua was sustained, with the indemnity increased to P30,000.00.