Case Digest: PEOPLE OF THE PHILIPPINES v. REY SUNGA, et al.

PEOPLE OF THE PHILIPPINES v. REY SUNGA, et al.

        Upon the discovery of the mutilated body of a high-school girl at a coffee plantation, an Information was filed before the Regional Trial Court (RTC) for Rape with Homicide against several suspects including Rey Sunga, Ramil Lansang, Inocencio Pascua, Jr., and Lito Octac as principals, and Locil Cui alias Ginalyn Cuyos as accomplice.

        Rey Sunga et al. filed with the RTC a petition for bail underscoring the weakness of the prosecution‘s evidence, there being no direct evidence against them. In the same proceeding, a motion was granted to discharge Locil to become a state witness while deferring the resolution of the bail petition.

        Through the testimony of Locil, the RTC reached to a decision convicting Sunga and Lansang as principals of the crime of Rape with Homicide and sentenced each to suffer the penalty of death, and Pascua as principal in the crime of Rape.

ISSUE:

Whether the guilt of Sunga et al. has been proven beyond reasonable doubt of the crime charged

HELD:

The testimony of a self-confessed accomplice or co-conspirator imputing the blame to or implicating his co-accused cannot, by itself and without corroboration, be regarded as proof to a moral certainty that the latter committed or participated in the commission of the crime. The testimony must be substantially corroborated in its material points by unimpeachable testimony and strong circumstances and must be to such an extent that its trustworthiness becomes manifest.

As an exception to the general rule on the requirement of corroboration of the testimony of an accomplice or co-conspirator-turned state witness, her testimony may, even if uncorroborated, be sufficient as when it is shown to be sincere in itself because it is given unhesitatingly and in a straightforward manner and full of details which, by their nature, could not have been the result of deliberate afterthought.

The Court is not in fact prepared to accord Locil credibly as a witness. Who can trust one who, in her early teens, gets pregnant, flees home and stays in a boarding house albeit she has no visible means of income to pay therefor, and carries an alias name to evade being traced by her mother and aunt?

Evidence to be believed should not only proceed from the mouth of a credible witness but should also be credible in itself such as the common experience and observation of mankind can approve as probable under the circumstances.

The observations pertaining to both the weak, incomprehensible voice with which Locil gave her testimony, the improbability with which she was precisely made by appellants to be a witness to their crime, and the failure of her description of Pascua‘s eyes to match the latter‘s actual physical feature cannot but engender serious doubts as to the reliability of her testimony against all appellants. The Court thus finds her uncorroborated account to have failed the jurisprudentially established touchstone for its credibility and sufficiency, that of straightforwardness and deliberateness, as evidence to warrant appellants‘ conviction.