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People vs. Piedad, GR 131923, 5 December 2002
On 10 April 1996, Lactawan left her house at No. 2 Scout Bayoran, Barangay South Triangle, Quezon City, to follow Mateo, her husband, who had earlier gone. As she was walking by the gate of the company compound where they reside, she heard Piquero shouting for help because Mateo was being mauled by a group of men. She rushed out of the compound and saw her husband being beaten up by Niel Piedad, Richard Palma, Lito Garcia and five others. She tried to pacify the aggressors, but was beaten herself. Luz embraced Mateo in an effort to protect him. It was then that Niel picked up a large stone, measuring about a foot and a half, and struck Mateo’s head with it. Then, Lito approached Mateo’s side and stabbed him at the back, while Richard hit Mateo in the face. Mateo was rushed to the East Avenue Medical Center where he later died because of the injuries he sustained. Piedad , Garcia and Palma were charged with Murder. Upon arraignment, all the accused pleaded not guilty to the charge. Trial ensued thereafter. The trial court rendered a decision, finding Piedad and Garcia guilty beyond reasonable doubt of the crime of murder with no modifying circumstances present, and sentenced each of them to suffer the penalty of reclusion perpetua pursuant to Article 248 of the Revised Penal Code. Piedad and Garcia were likewise held solidarily liable to indemnify the heirs of the victim Lactawan in the sum of P50,000.00. Richard Palma was acquitted on the ground of reasonable doubt. Piedad and Garcia appealed.
Whether or not the way that Piedad was identified by prosecution witnesses was suggestive and fatally flawed.
The claim by the defense that Piedad’s pre-trial identification was suggestive due to the absence of a police lineup is more theoretical than real. It must be pointed out that even before the incident, Luz Lactawan knew the accused. Fidel, on the other hand, knew Piedad because they played basketball together. Hence, the witnesses were not identifying persons whom they were unfamiliar with, where arguably, improper suggestion may set in. On the contrary, when the accused were presented before the witnesses, they were simply asked to confirm whether they were the ones responsible for the crime perpetrated. The witnesses did not incriminate the accused simply because they were the only ones presented by the police, rather, the witnesses were certain they recognized the perpetrators of the crime. Besides, there is no law which requires a police lineup before a suspect can be identified as the culprit of a crime. What is important is that the prosecution witnesses positively identify the persons charged as the malefactors. In this regard, the Court finds no reason to doubt the veracity of Luz’s and Fidel’s testimony. The records show that Luz and Fidel positively, categorically and unhesitatingly identified Piedad as the one who struck Mateo on the head with a stone, and Garcia as the one who stabbed Mateo on the back, thereby inflicting traumatic head injuries and a stab wound which eventually led to Mateo’s death. Indeed, if family members who have witnessed the killing of a loved one usually strive to remember the faces of the assailants, the Court sees no reason how a wife, who witnessed the violence inflicted upon her husband and who eventually died by reason thereof, could have done any less. It must be stressed that Luz was right beside her husband when the concrete stone was struck on his head, hence, Luz could not have mistaken the identity of the person responsible for the attack. She was only a foot away from Piedad before the latter hit Mateo on the head. Garcia on the other hand was identified by both Luz and Fidel as the one who was shirtless at the time of the incident. There was light from a bulb 5 meters away from the scene of the crime. Experience dictates that precisely because of the unusual acts of violence committed right before their eyes, eyewitnesses can remember with a high degree of reliability the identity of the criminals at any given time. Hence, the proximity and attention afforded the witnesses, coupled with the relative illumination of the surrounding area, bolsters the credibility of identification of Piedad, et. al. While Piedad and Garcia may have been suspects, they were certainly not interrogated by the police authorities, much less forced to confess to the crime imputed against them. Piedad and Garcia were not under custodial investigation. In fact, Piedad averred during cross-examination that the police never allowed them to say anything at the police station on the day they voluntarily presented themselves to the authorities.