Tuesday, November 9, 2021

Evaluation of the witnesses' credibility is a matter best left to the trial court.


"xxx.

Evaluation of the witnesses' credibility
is a matter best left to the trial court.

Indubitably, the credibility of the testimony of prosecution's prime witness Maramara is the meat of the instant controversy. Petitioners postulate that he is not a credible witness. They point out that there were inconsistencies in his testimonies vis-a-vis his confession, and that his declarations should be totally rejected considering his questionable reputation and personal background as evidenced by his previous conviction. Being a confessed conspirator, his testimony was procured from a polluted source. Moreover, he had the ill-motive of revenge against Labandero and Bug-atan considering that Labandero was a witness against Maramara in the killing of Lanogan while Bug-atan was responsible for his arrest on April 21, 1993.

We are not convinced.

Petitioners try to discredit Maramara by highlighting his alleged inconsistent statements in his extrajudicial confession and his testimony in court, i.e., he allegedly averred in his confession that Manatad and Bug-atan went to see him on April 9, 1993 whereas in his direct examination, he merely stated that there was only one person who went to him. Petitioners also invite our attention to the variance regarding the place where the meeting was held, whether it was at the house of Maramara's aunt or at the pier.

These perceived inconsistencies provide no persuasive reason for us to distrust the credibility of Maramara. They refer to minor details and not to the central fact of the crime. They are too trivial to affect his straightforward account of the killing of the victim and the complicity of the petitioners. It is settled that inconsistencies relating to minor details do not affect the creditworthiness of the witness testifying and that minor inconsistencies tend to show that the witnesses were not coached or rehearsed. This is a well- settled doctrine which need not require much documentation. The testimony of a witness must be considered in its entirety instead of in truncated parts. The technique in deciphering a testimony is not to consider only its isolated parts and anchor a conclusion on the basis of said parts.[16] At any rate, Maramara had adequately explained and properly corrected himself regarding these alleged inconsistencies during his examination in court.[17]

Maramara's previous conviction neither detracts his competency as a witness nor necessarily renders his testimony totally untrustworthy and inadmissible. While Maramara admitted to having been previously convicted in Criminal Case No. DU-3721, this circumstance does not necessarily make him or his testimony ipso facto incredible. The determination of the character of a witness is not a prerequisite to belief in his testimony.[18] His alleged bad reputation, even if true, should not sway the court in the evaluation of the veracity of his testimony. Other important factors should be considered in determining the inherent probability of his statements for a convicted person is not necessarily a liar. After all, conviction of a crime, unless otherwise provided by law, shall not be a ground for disqualification of witnesses.[19] More importantly, the testimony of Maramara who undeniably pleaded guilty in killing the victim should definitely be given more weight inasmuch as his testimony pertains in not insignificant points to the specific incident. It is to be noted that Dr. Crisostomo Abbu, the medical officer who conducted the post- mortem examination on the body of the victim, provided collaborating testimony regarding the location of the inflicted wound, thereby rendering more credible the testimonial account of Maramara. In fine, we defer to the trial court's finding, sustained by the appellate court, giving full weight and credit to Maramara's testimony. The trial court's findings regarding the witness's credibility are accorded the highest degree of respect.[20]

The Court finds the supposed enmity of Maramara not sufficient reason to impel him to implicate petitioners in the killing of the victim. While it may be conceded that Labandero was a witness against Maramara in a murder case while Bug-atan was instrumental in Maramara's arrest, still, the defense was unable to conclusively establish that Maramara was ill-motivated in denouncing petitioners as his co-conspirators in the commission of the crime. There is no proof that Maramara had the intention to pervert the truth and prevaricate just to implicate petitioners in so serious a crime as murder. In fact, the trial court did not perceive such improper motivation on his part. All that petitioners had are pure speculation and afterthought. The absence of evidence of improper motive tends to indicate that a witness's testimony is worthy of full faith and credence.[21]

We see no reason to deviate from the trial court's keen observation that the credibility of Maramara as witness has remained intact notwithstanding the attempts of the defense to demolish it. Hence, his testimony should be given full weight and credit. We likewise agree with the appellate court in holding that the trial court did not err in appreciating the testimony of Maramara since it was corroborated by the testimonies of other witnesses and was given unhesitatingly in a straightforward manner and full of details which could not have been the result of deliberate afterthought. His testimony is too rich in details brought out during his examination in court which cannot simply be swept aside as mere fabrication. The declarations of the other prosecution witnesses, individually considered, may have been circumstantial and lacking in full details. But their combined testimonies somehow supplement in no small measure the testimonial account of Maramara. As we and the courts below cautiously determined, they strengthen the prosecution's evidence not only with respect to the fact of killing but also on the conspiracy angle of the case.

Xxx."

VIRGILIO BUG-ATAN, BERME LABANDERO GREGORIO MANATAD PETITIONERS, VS. THE PEOPLE OF PHILIPPINES, Respondent. G.R. No. 175195, September 15, 2010.

https://www.chanrobles.com/cralaw/2010septemberdecisions.php?id=319