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EDMUNDO ESCAMILLA Y JUGO v. PEOPLE

FACTS:

The petitioner, Edmundo Escamilla, was convicted of frustrated homicide. The incident happened on August 1, 1999, when a brawl ensued at the corner of Estrada and Arellano Streets in Manila. The victim, Virgilio Mendol, who is a tricycle driver, was about to ride his tricycle when petitioner shot him four times, hitting him in the upper right portion of his chest. Mendol survived because of timely medical attention. The Assistant City Prosecutor of Manila filed an Information charging petitioner with frustrated homicide. Petitioner pleaded not guilty, and during trial, the prosecution presented testimonies of eyewitnesses, including Mendol, who positively identified petitioner as the shooter. The defense presented their own witnesses, including petitioner himself and his wife, as well as the results of a paraffin test and transcripts of the court's ocular inspection of the crime scene. The Regional Trial Court (RTC) found petitioner guilty of frustrated homicide and sentenced him to an indeterminate sentence of six months and one day of prision correccional as a minimum, to eight years and one day of prision mayor as a maximum. The Court of Appeals (CA) upheld the RTC's decision, noting the credibility of the prosecution witnesses and the victim's positive identification of petitioner. Petitioner filed a Motion for Reconsideration, which the CA denied. Hence, the petition for review on certiorari before the Supreme Court.

ISSUES:

  1. Whether the Court of Appeals erred in upholding the trial court's appreciation of the credibility of the prosecution witnesses.

  2. Whether the Court of Appeals erred in giving more weight to the positive identification of the accused by the victim over the defense of alibi.

  3. Whether the Court of Appeals erred in considering the paraffin test result of the accused inconsequential when there is a positive identification.

RULING:

  1. The Court of Appeals did not err in upholding the trial court's appreciation of the credibility of the prosecution witnesses. The trial court, being in the best position to observe their demeanor, found the positive testimonies of the witnesses more credible than the defense of alibi.

  2. The Court of Appeals did not err in giving more weight to the positive identification of the accused by the victim over the defense of alibi. The victim's positive and unequivocal identification of the accused totally destroyed his defense of alibi.

  3. The Court of Appeals did not err in considering the paraffin test result of the accused inconsequential when there is a positive identification. A paraffin test is not a conclusive proof that a person has not fired a gun and is deemed inconsequential when there is a positive identification.

PRINCIPLES:

  • The credibility of witnesses is within the domain of the trial court, which has a better position to observe their demeanor.

  • Positive and unequivocal identification of the accused by the victim can outweigh the defense of alibi.

  • A paraffin test is not a conclusive proof of whether a person has fired a gun. It is deemed inconsequential when there is a positive identification.