PEOPLE OF THE PHILIPPINES, vs. ARTURO MAUYAO y LORENZO.
- G.R. Number: G.R. No. 84525
- Promulgated: 1992-04-06
- Ponente: Melencio-Herrera, J.
Doctrine
Minor inconsistencies and contradictions in witness declarations do not destroy credibility and may even enhance truthfulness by showing lack of rehearsal.
Findings on witness credibility by a trial judge who observed demeanor will not be disturbed on appeal except for evident abuse.
Admissions obtained in violation of constitutional rights are inadmissible, but exclusion of such documents does not preclude conviction if other evidence establishes guilt beyond reasonable doubt.
Facts
Accused-appellant Arturo Mauyao was convicted for 'pushing' five tea bags of marijuana and sentenced to life imprisonment and a P20,000 fine.
On 19 August 1991 Mauyao filed a Motion to Withdraw Appeal, retracted it by letter dated 11 January 1992, and the Court allowed withdrawal on 19 February 1992.
He was apprehended in a buy-bust operation and convicted based primarily on testimony of the arresting officers and certain questioned documents.
Issues
Whether the trial court erred in crediting the prosecution witnesses despite alleged inconsistencies in their accounts of the buy-bust operation.
Whether admissions or documents allegedly obtained in violation of the accused's constitutional rights were admissible and determinative of guilt.
Ruling
The Court affirmed the conviction, holding the trial court did not err in crediting the prosecution witnesses; minor inconsistencies were de minimis and did not undermine credibility.
Although admissions obtained in violation of constitutional rights are inadmissible, the Court found such documents nonessential here because other unshaken evidence established guilt beyond reasonable doubt.
Keywords
G.R. No. 84525, marijuana, life in prison, fine of P20,000.00, Motion to Withdraw Appeal, prosecution evidence, Narcotics Unit of the Western Police District, surveillance, illegal sale of marijuana, buy-bust operation, poseur-buyer, marked money, arresting officer, search and seizure warrant, Receipt of Property Seized, admission without the presence of counsel, Booking Sheet and Arrest Report, NBI Forensic Chemist, microscopic, chemical and chromatographic examinations, extortion