PEOPLE v. ANGELO ARCEO Y MALI

FACTS:

The case involves an appeal by Angelo Arceo, who was convicted of robbery with homicide along with his co-accused Ramil Cecilio. They were charged before the Regional Trial Court of Manila for forcibly snatching a wristwatch from Delfin Manalese and stabbing him in the chest, resulting in his death. Both accused pleaded not guilty. The trial court found them guilty and sentenced them to reclusion perpetua. Only Angelo Arceo appealed the conviction. The prosecution presented witnesses who witnessed the incident and a medico-legal officer who conducted the victim's autopsy. The defense, on the other hand, presented testimonies denying the accused's involvement in the crime, as well as their alibi and character testimonies from neighbors.

ISSUES:

  1. Whether the witnesses for the prosecution are credible.

  2. Whether the supposed errors and inconsistencies in the testimonies of the prosecution witnesses are material or fatal.

  3. Whether the lone testimony of the witness is sufficient to support a conviction.

  4. Whether the complainant/witness can be impeached based on a pending complaint against him.

  5. Whether the defense of alibi is valid in this case.

RULING:

  1. The court held that the witnesses for the prosecution are credible. The court emphasized that inconsistencies and contradictions regarding minor details do not destroy the credibility of witnesses. Inconsistencies that do not impair the identification of the accused are not fatal to the testimony. Discrepancies in the testimony of witnesses who were in a state of surprise and fright add credence and veracity to their categorical, straightforward, and spontaneous testimony. The court further noted that variations in the testimonies of different witnesses can be attributed to their diverse impressions and perceptions of a startling event. The trial court's findings on the credibility of the witnesses should not be disturbed on appeal unless there are facts or circumstances that were overlooked and that may affect the result of the case. In this case, the trial court found the testimonies of the witnesses clear, direct, spontaneous, sincere, and candid, with no motive to testify falsely against the accused.

  2. The lone testimony of the witness is sufficient to support a conviction because it is credible and positively identifies the accused as the perpetrators of the crime.

  3. The complainant/witness cannot be impeached based on a pending complaint against him unless there is a previous conviction by final judgment. The existence of a pending information is not enough to discredit a witness.

  4. The defense of alibi is not valid in this case because the accused failed to demonstrate that it was physically impossible for him to be at the scene of the crime. Alibi is one of the weakest defenses and cannot prevail over positive identification by prosecution witnesses.

PRINCIPLES:

  • Inconsistencies and contradictions regarding minor details do not destroy the credibility of witnesses.

  • Inconsistencies in the principal eyewitness' testimony that do not impair the identification of the accused are not fatal.

  • Discrepancies or minor details in the testimonies of witnesses in a state of surprise and fright add credibility and veracity to their testimony.

  • Variations in the testimonies of different witnesses can be attributed to their diverse impressions and perceptions of a startling event.

  • The findings of the trial court on the credibility of witnesses carry great weight and should not be disturbed on appeal, unless there are facts or circumstances that were overlooked and that may affect the result of the case.

  • A conviction can be based on the lone but credible testimony of a witness.

  • To impeach a witness, previous conviction by final judgment is required, and the existence of a pending information is not sufficient.

  • Alibi defense must demonstrate that it was physically impossible for the accused to be at the scene of the crime. It cannot prevail over positive identification by prosecution witnesses.