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PEOPLE v. JIMMEL SANIDAD

FACTS:

Accused-appellants JIMMEL SANIDAD and PONCE MANUEL, along with two unidentified companions, were convicted by the trial court for the complex crime of murder and multiple attempted murder. On January 16, 1999, a group of individuals left Budac, Tagum, Abra in a passenger jeepney to attend a barangay fiesta in Langangilang, Abra. Accused-appellants and several other residents of Lagangilang joined them in drinking during the fiesta. Early in the morning of January 17, the group headed home on the same jeepney. As the jeepney approached a plantation, accused-appellants and their companions ambushed the vehicle, showering it with bullets. The passengers tried to evade their attackers, but the vehicle eventually stalled. Accused-appellants then caught up with the jeepney, set it on fire, and left the scene. Despite the ambush and ensuing fire, most of the passengers survived with minor injuries, except for one passenger who was found dead. Autopsy results showed that the cause of death was burns. Accused-appellants denied involvement in the ambush, claiming they were at home sleeping at the time. The trial court convicted them based on the credible testimonies of the victims and other prosecution witnesses. Accused-appellants appealed their conviction, but the Supreme Court affirmed it, finding that the prosecution presented sufficient evidence and the trial court's assessment of witness credibility was not arbitrary.

ISSUES:

  1. Whether the minor inconsistencies and inaccuracies in the testimonies of the witnesses affect their credibility.

  2. Whether the positive identification of the accused-appellants by the witnesses is sufficient evidence for conviction.

  3. Whether the defense of alibi presented by the accused-appellants is credible.

  4. Whether the delay in reporting the crime to the authorities affects the evidentiary value of the witnesses' testimony.

  5. Whether the accused-appellants are guilty of the complex crime of murder and multiple attempted murder.

  6. Whether the penalty of death should be imposed on the accused-appellants.

RULING:

  1. The minor inconsistencies and inaccuracies in the testimonies of the witnesses do not affect their credibility. Inconsistencies and inaccuracies in the testimonies which refer to minor and insignificant details do not destroy the credibility of witnesses. Such minor inconsistencies and inaccuracies even manifest truthfulness and candor and do not raise suspicion of rehearsed testimony.

  2. The positive identification of the accused-appellants by the witnesses is sufficient evidence for their conviction. The victims, who were eyewitnesses to the crime and almost got killed during the ambush, positively identified the accused-appellants in open court. The victims had sufficient opportunity to identify the perpetrators, and their familiarity with the accused-appellants renders a mistaken identification unlikely.

  3. The defense of alibi presented by the accused-appellants is not credible. The accused-appellants claimed that they were in their respective houses at the time of the ambush, but their proximity to the crime scene makes it physically possible for them to be at the locus criminis. Alibi must not only prove the presence of the accused at another place but also demonstrate that it would be physically impossible for the accused to be at the scene of the crime.

  4. The delay in reporting the crime to the authorities does not affect the evidentiary value of the witnesses' testimony. Delay in reporting a crime is not uncommon and is not by itself a setback to the evidentiary value of witnesses' testimony. A well-founded fear of reprisal or the shock experienced by witnesses can justify the temporary silence of witnesses in reporting the crime.

  5. The accused-appellants are guilty of the complex crime of murder and multiple attempted murder. The court found that conspiracy and treachery attended the commission of the crime. The concerted actions of the accused-appellants clearly evinced conspiracy, and their successive shots did not give the victims any opportunity to defend themselves. The court held that accused-appellants had murder in their hearts when they waylaid their victims.

  6. The penalty of death is imposed on the accused-appellants. The court applied Art. 48 of The Revised Penal Code, which provides that when a single act constitutes two or more grave or less grave felonies, the penalty for the most serious crime shall be imposed in its maximum period. In this case, the most serious offense is murder, and the penalty for murder is reclusion perpetua to death. The court ruled that the imposition of the maximum penalty is in accordance with the law.

PRINCIPLES:

  • Inconsistencies and inaccuracies in the testimonies of witnesses which refer to minor and insignificant details do not destroy their credibility.

  • Positive identification of the accused by eyewitnesses to the crime is sufficient evidence for conviction.

  • The defense of alibi must not only prove the presence of the accused at another place but also demonstrate that it would be physically impossible for the accused to be at the scene of the crime.

  • Delay in reporting a crime to the authorities does not diminish the evidentiary value of witness testimony if adequately justified by acceptable explanations such as fear of reprisal or shock experienced by witnesses.

  • Conspiracy and treachery can be proved even without direct evidence of a prior agreement to commit the crime.

  • In a complex crime, although two or more crimes are actually committed, they constitute only one crime in the eyes of the law.

  • When a conspiracy animates several persons with a single purpose, their individual acts done in pursuance of that purpose are looked upon as a single act, giving rise to a single complex offense.

  • The penalty for the most serious offense in a complex crime should be imposed in its maximum period.