Teñido vs People of the Philippines
G.R. No. 211642 March 09, 2016
Facts: This resolves the Petition for Review on Certiorari1 under Rule 45 of the Rules of Court, from the Decision dated September 20, 2013 of the Court of Appeals (CA) in CA-G.R. CR No. 34325 which affirmed with modification the Decision dated May 23, 2011 of the Regional Trial Court (RTC) of Manila, Branch 25, in Criminal Case No. 88-67398 finding Nelson Teñido y Silvestre (Teñido) guilty beyond reasonable doubt of the crime of Robbery in the manner, date and circumstances stated in the criminal information accusing him and his co-accused, Rizaldo Alvarade y Valencia (Alvarade), as follows: That on or about June 22, 1988, in the City of Manila, Philippines, the said accused, conspiring and confederating together and helping each other, did then and there wilfully, unlawfully and feloniously, with intent of gain and without the knowledge and consent of the owner thereof, by means of force upon things, break into and enter house no. 1250, Kahilom I, Pandacan, Manila, inhabited by Lolita Sus de Enriquez, by the[n] and there destroying the chicken wire of their door at the store and removing a small piece of lawanit nailed to it, and passing through the same, an opening not intended for entrance or egress, and once inside, took, stole and carried away therefrom cash money amounting to P600.00, one (1) male wristwatch (Rolex) worth P2,000.00, one (1) Citizen wristwatch worth P995, one (1) gold ring with stone (brillante) worth P1,500.00, one (1) wallet containing cash money of P1,200.00, and one (1) gold[-]plated Seiko 5 watch worth P1,200.00 with a total value of P7,495.00, belonging to Lolita Sus de Enriquez, to the damage and prejudice of the said owner in the aforesaid amount of P7,495.00, Philippine currency. Contrary to law.
Issue: Whether or not a review on the credibility of a witness is a question of fact outside the bounds of a petition for certiorari under Rule 45.
Held: Yes. Questions pertaining to the credibility of a witness are factual in nature and are, generally, outside the ambit of the Court’s appellate jurisdiction. It is a settled rule that a petition for review on certiorari under Rule 45 of the Rules of Court shall raise only questions of law. “A question that invites a review of the factual findings of the lower tribunals or bodies is beyond the scope of this Court’s power of review and generally justifies the dismissal of the petition.”
Moreover, it is axiomatic that absent any showing that the trial court overlooked substantial facts and circumstances that would affect the final disposition of the case, appellate courts are bound to give due deference and respect to its evaluation of the credibility of an eyewitness and his testimony as well as its probative value as it was certainly in a better position to rate the credibility of the witnesses after hearing them and observing their deportment and manner of testifying during the trial.
The Court finds no cogent reason to depart from the foregoing tenets especially in view of the absence of any exceptional circumstances that will justify a re-evaluation of the RTC’s factual findings.
The fact of delay attributed to a prosecution witness cannot be taken against her. What is important is that her testimony regarding the incident bears the earmarks of truth and dependability. Time and again, the Court has stressed:
Delay in revealing the identity of the perpetrators of a crime does not necessarily impair the credibility of a witness, especially where sufficient explanation is given. No standard form of behavior can be expected from people who had witnessed a strange or frightful experience. Jurisprudence recognizes that witnesses are naturally reluctant to volunteer information about a criminal case or are unwilling to be involved in criminal investigations because of varied reasons. Some fear for their lives and that of their family; while others shy away when those involved in the crime are their relatives or townmates. And where there is delay, it is more important to consider the reason for the delay, which must be sufficient or well-grounded, and not the length of delay.
Guinto sufficiently explained that she got nervous and frightened. Further, there is no showing that Guinto was impelled by any ill motive to fabricate facts and attribute a serious offense against Teñido. Where there is no evidence to indicate that the prosecution witness was actuated by improper motive, the presumption is that she was not so actuated and that her testimony is entitled to full faith and credit.
Black n white 