PEOPLE OF THE PHILIPPINES, vs. LUCIANO JUMAMOY Y AÑORA, alias "JUNIOR".
- G.R. Number: G.R. No. 101584
- Promulgated: 1993-04-07
Doctrine
Findings of fact on witness credibility by the trial court are entitled to great respect and will not be disturbed on appeal absent a showing the court overlooked, misunderstood or misapplied material facts or circumstances.
Alibi is generally a weak defense but may be credited; the accused claiming alibi must prove it was impossible for him to be at the scene because he was elsewhere.
Conflicts among eyewitnesses—here, differing accounts about the source and sufficiency of light—bear on the reliability of positive identification.
Facts
The case caption shows People of the Philippines as plaintiff-appellee and Luciano Jumamoy y Añora, alias "Junior," as accused-appellant. (caption and counsel listed).
The trial court (Branch 3, RTC Tagbilaran City) found the accused guilty in Criminal Case Nos. 5064 and 5065; the Supreme Court affirmed those convictions. (disposition).
Three alleged eyewitnesses testified but their accounts were inconsistent, especially as to the source and sufficiency of lighting for identification. (eyewitness inconsistencies).
The accused pleaded alibi; the Court observed that alibi is generally a weak defense and must prove impossibility of being at the scene because he was elsewhere. (alibi rule).
Issues
Whether the trial court's findings on witness credibility should be disturbed on appeal.
Whether the accused's alibi defense was established so as to negate his conviction.
Ruling
The Supreme Court affirmed the RTC convictions in Criminal Case Nos. 5064 and 5065, with modification increasing indemnity from P30,000.00 to P50,000.00 and deleting the words "life imprisonment" from the dispositive portion.
Costs were ordered against the accused.