Case Digest: PEOPLE OF THE PHILIPPINES v. DANTE NARRA Y ARIOLA 404 SCRA 125 (2003)

PEOPLE OF THE PHILIPPINES v. DANTE NARRA Y ARIOLA 404 SCRA 125 (2003)

Witnesses are not expected to recall with accuracy or uniformity every single detail of the incident, given the frailty of human memory; as long as their testimonies dovetail on material points, the courts may not just disregard them. Appellant Dante Narra Y Ariola was found guilty beyond reasonable doubt by the Regional trial Court (RTC) on two consolidated cases of murder and homicide. Narra now comes to the Supreme Court contending, among others, that it was physically impossible for him to be at the scene, contrary to the claim of the witnesses. Moreover, he contends that the testimony given by the witnesses are inconsistent, contradictory, and doubtful and cannot be the sole bases for his conviction.

ISSUE:

Whether or not the witnesses gave credible testimonies which are sufficient to convict Narra of the crimes charged

HELD:

Narra, claiming that the prosecution failed to prove his guilt beyond reasonable doubt, draws attention to alleged inconsistent, conflicting and contradictory testimonies of prosecution witnesses. And Narra questions the credibility of Dula Bautista who testified only after eight (8) months from the occurrence of the incident; of Lita Manuel, who like Dula Bautista, was not listed as a witness for the prosecution and only volunteered to give her statement several months after the incident, upon the prodding of witness Manlangit; and of Brigida Viloria, a close friend of the Manlangits, whose testimony is suspicious and doubtful as she surfaced only after one year from the occurrence of the incident. With respect to Amangcas questioned testimony on when appellant alighted from the motorcycle and his recollection of Narra‘s footwear and length of his pants, any variation thereon is too insignificant to erode his credibility. It bears noting that right after the incident, Amangca picked up the empty bullet shells from the scene of the crime which he handed to the police, a reflection of his presence of mind and keen attention both of which enhance his capacity for correct observation. And he, also after the incident, gave a vivid, credible account of what transpired. What is important is that he positively identified Narra as the gunman soon after he was arrested. Amangcas credibility as a witness having been unimpeached and the credibility of his testimony having been unsuccessfully impeached, discussion of the corroborative testimony of the other prosecution witnesses becomes unnecessary. Suffice it to state that any discrepancies in their testimonies are too trivial to affect their credibility and in fact render them more believable as they preclude the possibility of rehearsal. For witnesses are not expected to recall with accuracy or uniformity every single detail of the incident, given the frailty of human memory. As long as their testimonies dovetail on material points, the courts may not just disregard them.