70 PEOPLE v SANCHEZ

Date: 23 August 2001 GR Number: GR 121039- Ponente:

45 Kapunan, J
Article III, Section 1, Wayne Michael L. Novera
Petitioners: PEOPLE OF THE PHILIPPINES Respondents: AYOR ANTONIO L. SANCHEZ,
GEORGE MEDIALDEA, ZOILO AMA, BALDWIN
BRION, LUIS CORCOLON, ROGELIO
CORCOLON, and PEPITO KAWIT
Doctrine: All the appellants relied on the defense of denial/alibi. However, positive
identification by credible witnesses of the accused as the perpetrators of the crime, as we
have consistently held, demolishes the alibi — the much abuse sanctuary of felons.
Moreover, except for the Mayor and Medialdea, the other appellants failed to present
corroborating testimonial evidence to buttress their respective alibi. The defense of alibi is
inherently weak especially when wanting in material corroboration. Categorical declarations
of witnesses for the prosecution of the details of the crime are more credible than the
uncorroborated alibi interposed by the accused. However, alibi becomes less plausible as a
defense when it is invoked and sought to be crafted mainly by the accused himself and his
immediate relatives. In fine, the defense of alibi is an issue of fact that hinges on the
credibility of witnesses, and the assessment of the trial court, unless patently and clearly
inconsistent, must be accepted.

Facts:
1. Accused-appellants were found guilty beyond reasonable doubt of seven (7) counts of
rape with homicide on seven counts and sentenced each one of them to suffer the
penalty of seven reclusion perpetua.
2. The prosecution's version of the events was based mainly on the recollections of its
star witnesses Aurelio Centeno and Vicencio Malabanan — co-conspirators turned
state witnesses.
3. Both admitted having taken part in the abduction of Eileen Sarmenta and Allan
Gomez, but denied any personal involvement in the rape of Eileen and the twin
killings that followed.
Issue/s: Ruling:
The issue is W/N witnesses Centeno and Malabanan's credibility, whose YES
open-court narrations can be served as principal basis for the trial court's
rendition of a "guilty" verdict.
Rationale/Analysis/Legal Basis:

Discrepancies between sworn statements and testimonies made at the witness stand do not
necessarily discredit the witnesses. Sworn statements/affidavits are generally subordinated
in importance to open court declarations because the former are often executed when an
affiant's mental faculties are not in such a state as to afford him a fair opportunity of
narrating in full the incident which has transpired. Testimonies given during trials are much
more exact and elaborate. Thus, testimonial evidence carries more weight than sworn
statements/affidavits

Inconsistencies in the testimony of witnesses when referring only to minor details and
collateral matters do not affect either the substance of their declaration, their veracity, or the
weight of their testimony. Although there may be inconsistencies on minor details, the same
do not impair the credibility of the witnesses where there is consistency in relating the
principal occurrence and positive identification of the assailants, as in this case. Slight
contradictions in fact even serve to strengthen the sincerity of a witness and prove that his
testimony is not rehearsed. They are fail-safes against memorized perjury. Besides, errorless
testimonies cannot be expected especially when a witness is recounting details of a
harrowing experience. Even the most truthful witnesses can make mistakes but such
innocent lapses do not necessarily affect their credibility.