The Power of a Single Eyewitness Testimony in Philippine Robbery With Homicide Cases

In Philippine criminal law, a conviction does not always require a parade of witnesses. The Supreme Court has long held that the testimony of a single credible and trustworthy witness is sufficient to convict an accused, particularly when that witness had no motive to lie. The 1998 case of People v. Daraman (G.R. No. 126046, August 7, 1998) reaffirmed this doctrine in the context of robbery with homicide, offering clear guidance on how courts weigh eyewitness identification, alibi, and the testimony of co-accused individuals.

The Facts of the Case

On the evening of September 30, 1992, Fausto Labrador and his wife Lina were eating dinner in their home in Sto. Tomas, Davao, when a customer called out from their sari-sari store. Lina went to attend to the customer and soon called for her husband. When Fausto joined her, he found his wife trembling before two armed men who announced a hold-up.

One of the men, later identified as Edgardo Lumenarias, forced Lina into the house to open cabinets and drawers. The other man, Robert Daraman, guarded Fausto with a gun. Moments later, Fausto heard a gunshot. He saw Lumenarias picking up coins from the floor before both men fled. Lina had been shot in the head and died in her husband's arms. The robbers took about P2,000 in cash, two wristwatches, and motorcycle keys.

Lumenarias pleaded guilty. Daraman pleaded not guilty and was tried separately. The prosecution presented Fausto Labrador as the primary eyewitness, corroborated by Bienvenido Piamonte, a participant in the robbery who testified for the prosecution. Daraman denied involvement, presenting an alibi that he was working at a bullmill operation in Diwalwal, Monkayo, Davao at the time of the crime.

The Issue

The central question on appeal was whether the prosecution's evidence — anchored on the testimony of a single eyewitness, Fausto Labrador — was sufficient to convict Daraman of robbery with homicide beyond reasonable doubt.

The Court's Ruling

The Supreme Court affirmed Daraman's conviction. The Court reiterated the well-settled doctrine that the testimony of a single credible and trustworthy witness is sufficient to convict, especially when the witness was not shown to be motivated by bias or ill will.

The Court found Fausto Labrador's identification of Daraman to be direct, unequivocal, and credible. The store was well-lit, and Fausto had a clear view of Daraman, who pointed a gun at him from less than a yard away. Fausto testified that he saw Daraman's face clearly and recognized him without hesitation when the suspects were presented to him by police. He remained firm even under cross-examination and clarificatory questions from the trial court.

The Court rejected Daraman's argument that a witness cannot positively identify a stranger seen for the first time at night. Citing People v. Bracamonte (257 SCRA 380, June 17, 1996), the Court held that there is no legal requirement that a witness must personally know the offender for identification to be valid. If that were the rule, prosecutions would rarely succeed, since most crimes are committed by strangers to the victim.

The Value of Corroborating Testimony

While Piamonte's testimony corroborated Fausto's account on material points, the Court made clear that even without such corroboration, Fausto's testimony alone would have been sufficient. As the Court noted in People v. Nulla (153 SCRA 471, August 31, 1987), "witnesses are weighed, not numbered." A single witness's testimony may suffice for conviction if it is otherwise trustworthy and reliable.

The Court also addressed the defense's attack on Piamonte's credibility, noting that he had been assured immunity from prosecution. The Court held that testimony originating from a "polluted source" is not automatically inadmissible; rather, courts must scrutinize it carefully. The decision to exclude Piamonte from the Information was a prerogative of the prosecution.

Alibi and Denial Cannot Prevail

Daraman's defense of alibi and denial failed in light of positive identification. The Court reiterated that an affirmative testimony is far stronger than a negative one, especially when it comes from a credible witness. The alibi witnesses presented by the defense were found unreliable, with noticeable inconsistencies in their testimonies.

Penalty and Damages

The crime was committed in 1992, when the death penalty was proscribed by the Constitution. The Court therefore affirmed the trial court's imposition of reclusion perpetua under Article 294(1) of the Revised Penal Code, which penalizes robbery with homicide.

The Court also sustained the awards of P50,000 as civil indemnity for death, P20,000 as moral damages, P10,000 as exemplary damages (because the crime was committed with the aggravating circumstance of dwelling), and P19,000 as actual damages for burial expenses.

Practical Takeaways

• A single eyewitness's testimony can be enough to convict, provided it is credible, direct, and the witness had no motive to falsely implicate the accused.
• Positive identification by a victim carries great weight, especially when the crime scene was well-lit and the witness had a clear view of the offender.
• An alibi defense is weak against positive identification, particularly when corroborating witnesses are found unreliable.
• Courts weigh the quality of witnesses, not their number. Corroboration strengthens a case but is not always legally required.
• The prosecution's decision on who to charge and who to present as a witness is a matter of prosecutorial discretion.

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