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PEOPLE v. JOSE ENCARNACION MALIMIT

FACTS:

On April 15, 1991, Onofre Malaki was attending to his store while his houseboy, Edilberto Batin, was cooking in the kitchen at the back of the store. Florencio Rondon, a farmer, arrived at the store to purchase chemical for his rice farm. Batin went to the store to ask his employer if supper is to be prepared and was shocked to see appellant Jose Malimit coming out of the store with a bolo. Onofre Malaki was lying on the floor, injured and covered in blood. Rondon, who was outside, also saw appellant rushing out of the store with a blood-stained bolo. Batin immediately sought help and met Rondon outside the store. They went to the nearby house of Malaki's brother-in-law to inform him of the incident. When they went back to the store, they found Malaki's lifeless body in a pool of blood with the store's drawer ransacked and Malaki's wallet missing. Appellant was charged with and convicted of robbery with homicide and sentenced to reclusion perpetua. Appellant appeals his conviction and raises several errors, including the alleged delay in the identification of the appellant by the witnesses. It is argued that the witnesses only identified the appellant several months after the incident.

ISSUES:

  1. Whether the trial court erred in giving credence to the testimonies of the prosecution witnesses despite the delay in identifying the accused-appellant.

  2. Whether the trial court erred in admitting as evidence the wallet and its contents, which were allegedly obtained in violation of the constitutional rights of the accused.

  3. Whether the trial court erred in convicting the accused-appellant despite insufficient evidence to prove his guilt beyond reasonable doubt.

RULING:

  1. Credibility of Witnesses

    The Supreme Court found the appellant's contentions regarding the delay in witness identification to be without merit. The Court noted that the testimonies of the witnesses were corroborated by ample testimonial evidence and that delay in identifying the accused does not automatically render their testimonies unreliable. The Court further emphasized that findings of the trial court regarding witness credibility are generally given the highest degree of respect.

  2. Admissibility of Wallet and Contents

    The Court did not find merit in the claim that the wallet and its contents were obtained in violation of the constitutional rights of the accused. It ruled that the right against self-incrimination does not apply to object evidence like the wallet and its contents. The Court also held that even if these pieces of evidence were deemed inadmissible, other evidence and circumstances sufficiently established the appellant's guilt.

  3. Sufficiency of Evidence

    The Court found the evidence presented by the prosecution sufficient to sustain the appellant's conviction. The Court emphasized that circumstantial evidence can suffice for conviction if it forms an unbroken chain leading to a fair and reasonable conclusion that the accused is guilty. The Court found that the prosecution had satisfied the requirements for the sufficiency of circumstantial evidence.

PRINCIPLES:

  • Credibility of Witnesses The Court accords great respect to the trial court’s findings on the credibility of witnesses, especially when corroborated by ample testimonial evidence.

  • Right Against Self-Incrimination This right is limited to testimonial compulsion and does not extend to object evidence.

  • Sufficiency of Circumstantial Evidence Conviction can be based on circumstantial evidence if it complies with required essential requisites, forming an unbroken chain leading to a fair and reasonable conclusion of the accused's guilt.

  • "Miranda Rights" Infractions render inadmissible only the extrajudicial confession or admission made during custodial investigation but do not affect the admissibility of other relevant evidence obtained during such an investigation.

  • Possession of Stolen Property Possession of stolen property can give rise to a presumption that the possessor is the thief, barring contrary evidence.

  • Judicial Notice of Natural Reticence The Court recognizes the natural reticence of individuals to get involved in criminal cases against neighbors.