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PEOPLE v. MARK IAN LIBUNAO Y MARIANO

FACTS:

Appellant was charged with murder for dragging and hitting a traffic enforcer with a motor vehicle, causing his death. Witnesses testified on the events that transpired. Tongco witnessed the victim apprehend appellant's vehicle for a traffic violation. The vehicle then sped away, causing the victim to fall and sustain head injuries. Liton heard a noise and saw the victim lying on the ground while a maroon wagon sped away. Montipio saw the victim apprehend the appellant's vehicle and saw appellant push the victim aside. The vehicle suddenly sped away, dragging the victim and rendering him unconscious. The trial court granted appellant's motion for bail. The court found that the prosecution was able to prove appellant's identification as the driver of the vehicle but the qualifying circumstance of the use of a vehicle was not present. The motions for reduction of bail and release of the vehicle were subsequently denied. The prosecution continued presenting its evidence.

The prosecution adopted the evidence presented during the bail hearing and presented testimonies of Acosta (wife of the deceased), Renegin (investigator of the case), and Dr. Lim (forensic pathologist who performed the autopsy on the deceased). Acosta testified that her husband was the family's breadwinner and they have three children. Her husband sustained head injuries in the accident and died four days later. Renegin conducted an investigation and verified the vehicle involved. The vehicle was registered under the name of Borguete, but appellant was driving it at the time of the accident. Dr. Lim confirmed that the cause of death was injuries from the motor vehicular accident. The defense admitted the authenticity of the certificate of employment and compensation issued by the MMDA, which established the deceased's monthly income. The appellant filed a Motion for Waiver of Presentation of Evidence for the Defense. The RTC convicted appellant of homicide and sentenced him to prison and ordered him to pay damages to the heirs of the deceased.

ISSUES:

  1. Whether the identification of the appellant as the perpetrator of the crime was proven beyond reasonable doubt.

  2. Whether the appellant's claim of illegal arrest is valid.

  3. Whether the witness's identification of the appellant as the driver of the vehicle is reliable.

  4. Whether the distance and circumstances surrounding the witness's observation cast doubt on his identification.

  5. Whether the identification of the accused as the driver of the Isuzu Sportivo is reliable.

  6. Whether the doubt in the identification should be considered in favor of the appellant.

RULING:

  1. The Court ruled that the identification of the appellant as the perpetrator of the crime was proven beyond reasonable doubt. The trial court and the Court of Appeals both found that the witness's testimony was credible and that he saw the appellant driving the vehicle. The trial judge's evaluation of the witness's credibility is accorded the highest respect, and absent any overlooked or misinterpreted facts or circumstances, the Court defers to the trial court's findings.

  2. The Court ruled that the appellant's claim of illegal arrest is not valid. The trial court found that the appellant voluntarily submitted to the jurisdiction of the court by not objecting to the irregularity of his arrest before his arraignment and by pleading not guilty and actively participating in the trial. As a result, he waived his right to question the validity of his arrest.

  3. The Court found that the witness's identification of the appellant as the driver of the vehicle is not reliable. The distance between the witness and the tinted, closed window of the vehicle, along with the witness's divided attention and short period of time to observe the incident, cast doubts on his identification. Additionally, there was no prior description of the driver provided by the witness.

  4. The appellant is acquitted on the ground of reasonable doubt. The doubt created in the identification of the driver of the Isuzu Sportivo should be considered in favor of the appellant.

PRINCIPLES:

  • In cases where the identity of the accused is a crucial issue, the prosecution must establish the identity of the accused beyond reasonable doubt.

  • Positive identification, when categorical and consistent and without any showing of ill motive on the part of the eyewitness, prevails over alibi or denial.

  • When a witness's identification is questionable due to distance, visibility, and other circumstances, the court must exercise caution in accepting such identification as reliable evidence.

  • In cases where identification of the accused is made by a sole witness and the judgment depends entirely on the reliability of the identification, great care should be taken in considering the identification.

  • Doubt in the identification of the accused should be resolved in favor of the appellant.