Reasonable Doubt Prevails: Inconsistent Testimony Leads to Acquittal in Robbery Case

The Supreme Court has reminded trial courts that a conviction must rest on proof beyond reasonable doubt, not merely on the testimony of a single witness whose statements are riddled with material contradictions. In Viernes v. People (G.R. No. 161970, June 30, 2006), the Court acquitted an accused of robbery after finding that the prosecution's lone eyewitness gave inconsistent accounts of the crime on crucial points.

The Facts of the Case

On November 15, 1992, Josefina dela Cruz and her husband Ronaldo Lopango were riding a passenger jeepney when several co-passengers declared a hold-up. Lopango resisted and was stabbed three times, later dying from his wounds. Josefina fell from the jeepney during the commotion.

Hours after the incident, Josefina gave a sworn statement to the Caloocan police. In that statement, she said the incident happened in Caloocan City and, when asked what was taken from them, she categorically answered, "Wala pong naholdap sa amin" (nothing was taken from us). Three days later, however, she executed another sworn statement before the Manila police, this time claiming the robbery occurred in Manila and that the robbers took her bag containing clothes and P3,000 cash.

The accused, Dundee Viernes, was charged with violation of Presidential Decree No. 532 (the Anti-Piracy and Anti-Highway Robbery Law). He pleaded not guilty and presented an alibi, claiming he was arrested while walking home from fetching a cousin for his mother's birthday celebration.

The Issue

The central issue was whether the prosecution had proven the accused's guilt beyond reasonable doubt, given the inconsistencies in the lone witness's testimony.

The Ruling

The Supreme Court ruled in favor of the accused, holding that his guilt was not proven beyond reasonable doubt.

The Court identified several material inconsistencies in Josefina's testimony. First, her sworn statement before the Caloocan police placed the incident in Caloocan City and stated that nothing was taken from her. Her later statement before the Manila police placed the incident in Manila and claimed she lost P3,000. Second, in her sworn statement, she said her husband fell from the jeepney and she "let go" of the vehicle. In court, however, she claimed the accused "pushed" her and her husband off the jeepney. Third, she stated in her sworn statement that her belongings were never recovered, but testified in court that the accused returned her things "one by one."

While the Court acknowledged the general rule that discrepancies between a witness's sworn statement and courtroom testimony do not automatically discredit the witness, it noted an important exception: when the omission or contradiction refers to a very important detail of the incident that an eyewitness would not be expected to fail to mention, or when the narration in the sworn statement substantially contradicts the testimony in court.

The Court found that Josefina's explanation for the inconsistency—that she forgot to mention the loss of her bag because of her husband's death—taxed credulity. The hold-up occurred only three hours before she gave her first statement, and she had categorically stated that nothing was taken, not merely omitted the detail.

Practical Takeaways

• Proof beyond reasonable doubt is the constitutional standard. A conviction cannot stand on testimony that is inconsistent on material points, even if the witness is the sole prosecution witness.
• Sworn statements matter. Material contradictions between an affidavit and courtroom testimony can destroy a witness's credibility, especially when the affidavit was executed shortly after the incident.
• The "one witness" rule has limits. While Philippine law allows conviction based on the testimony of a single credible witness, that testimony must be positive, credible, and free from material inconsistencies.
• Trial courts must scrutinize credibility assessments. Where a trial court overlooks facts or circumstances of significance, its assessment of witness credibility may be set aside on appeal.
• Alibi, though weak, can prevail when the prosecution's case is weaker. Even an unimpressive defense can succeed when the prosecution fails to meet its burden of proof.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.