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PEOPLE v. MELITA SINCO

FACTS:

The appellant, Melito Sinco, was accused of murder with double attempted murder. The information alleged that on September 2, 1993, in San Juan, Ilocos Sur, Sinco conspired and helped another person in assaulting, attacking, and shooting Bonifacio Vanadero, Nelson Sarmiento, and Justino Sarmiento. Justino Sarmiento died as a result of the attack.

On the day of the incident, Vanadero was driving a tricycle with Justino Sarmiento and his son Nelson as passengers. They were on their way home after buying a cow in Barangay Bungro, Magsingal. As they were driving, two armed men appeared from the bushes near the highway. One had an armalite rifle and the other had a .45 caliber handgun. The armed men fired at them, with Justino Sarmiento getting hit and falling off the tricycle. Vanadero drove away, eventually stopping due to flat tires. He and Nelson Sarmiento then escaped on foot, leaving Justino behind.

Justino Sarmiento was taken to the Magsingal District Hospital but died later from the gunshot wound. A bullet was found embedded in his brain, and he had other injuries as well. Vanadero went to the police for assistance, and they recovered empty shells of an armalite rifle at the crime scene. The police entered in their blotter that the perpetrators were "unidentified."

Two years later, Vanadero and Nelson Sarmiento went to the provincial jail and identified Melito Sinco as one of the gunmen who shot them. They whispered and secretly pointed to a police officer that Sinco was the culprit. Vanadero and Sarmiento then executed sworn statements.

During the trial, Nelson Sarmiento corroborated Vanadero's account and claimed to have recognized Sinco as the gunman. He stated that he was familiar with Sinco because they used to play dice together at the cockpit arena in their barangay. Sinco presented alibi as his defense, stating that he was at the seashore with his live-in partner on the day of the incident.

The trial court convicted Sinco based mainly on Vanadero's identification, finding him credible. However, the appellant appealed, arguing that the trial court erred in giving weight to Vanadero's identification.

ISSUES:

  1. Whether the trial court erred in giving credence to the identification of the appellant by Bonifacio Vanadero.

  2. Whether the evidence presented by the prosecution is sufficient to prove the guilt of the accused beyond reasonable doubt.

  3. Whether the alibi and denial presented by the accused should result in his acquittal.

RULING:

  1. The Court agrees with the appellant's assertion that the trial court erred in giving credence to his identification by Bonifacio Vanadero. The prosecution failed to prove beyond reasonable doubt that the appellant was one of the gunmen. The witnesses' opportunity to view the culprits at the time of the crime was far from ideal, and the events narrated by the prosecution made it hardly possible to identify the offenders. The witnesses' descriptions of the assailant did not match the police report or provide any telling clues on the identity of the assailants. Moreover, Vanadero's identification of the appellant in secrecy evoked uncertainty and doubt. Therefore, the prosecution failed to establish the appellant's guilt beyond reasonable doubt.

  2. The Supreme Court reversed and set aside the decision of the Regional Trial Court and acquitted the accused on the ground of reasonable doubt. The Court found that the evidence presented by the prosecution was not strong enough to prove the guilt of the accused beyond reasonable doubt. Additionally, the alibi and denial presented by the accused, although weak, still cast doubt on his involvement in the crime. As the burden of proof is on the prosecution to establish the guilt of the accused, and they failed to do so, the accused deserves exoneration.

PRINCIPLES:

  • The first duty of the prosecution in a criminal case is to prove the identity of the perpetrator of the crime beyond reasonable doubt.

  • In resolving the admissibility of out-of-court identification of suspects, courts adopt the totality of circumstances test, which considers factors such as the witness' opportunity to view the criminal, the witness' degree of attention, the accuracy of any prior description given, the level of certainty demonstrated, the length of time between the crime and the identification, and the suggestiveness of the identification procedure.

  • Evidence must not only proceed from the mouth of a credible witness but also be credible, reasonable, and in accord with human experience.

  • Delay in reporting the identity of the perpetrator or filing a criminal complaint may impair the credibility of a witness, especially when there is no compelling or rational explanation for the delay.

  • Eyewitness identification based solely on the attire of the assailant may be considered weak and lacking in probative value.

  • Suggestiveness in the identification process, such as the presence of prior knowledge or external influences, may render the identification unreliable.

  • The evidence presented by the prosecution must be sufficient to overcome the presumption of innocence and establish guilt beyond reasonable doubt.

  • The burden of proof is on the prosecution to establish the guilt of the accused beyond reasonable doubt.

  • The strength of the defense evidence, such as alibi and denial, can cast doubt on the guilt of the accused.

  • If the prosecution fails to discharge its duty of proving the guilt of the accused beyond reasonable doubt, the accused should be acquitted by constitutional mandate.