CASE DIGEST
People v. Campos
G.R. No. 252212, [July 14, 2021]
SECOND, LOPEZ, M.V
Robbery with
homicide; Totality of Circumstance
In evaluating out-of-court
identifications, the court must consider the totality of the circumstances,
including factors such as the witness's opportunity to view the criminal, the
degree of attention, accuracy of prior descriptions, time lapse between the
crime and identification, level of certainty demonstrated, and the
suggestiveness of the identification procedure. The case establishes that a
positive identification, supported by these factors, can be deemed admissible
and reliable. The positive identification of the accused by credible witnesses, if not
tainted by suggestiveness or procedural flaws, prevails over defenses such as
alibi and denial.
On April 20, 2003, around 8:00 p.m.,
Emeliza P. Empon (Emeliza), her boyfriend Eric Sagun (Eric), and neighbor
Marilou Zafranco-Rea (Marilou) were in Emeliza's house. While having dinner, an
armed man entered, took Emeliza's cellphone, and shot her in the chest, causing
her death. Eric and Marilou reported the incident to the police, describing the
suspect as "[m]edyo malaki katawan." Acting on information, the
police found a man matching the description, arrested him, and recovered a .38
caliber firearm. The arrested man was identified as Roberto G. Campos
(Roberto). Roberto pleaded not guilty, claiming he was at a friend's house
during the incident. In his defense, Roberto's claims of police misconduct,
lack of paraffin test results, and inconsistencies in eyewitness accounts. The
RTC convicted Roberto of robbery with homicide based on Eric and Marilou's
positive identification. The validity of the out-of-court identification
made during a police lineup is the core issue in this appeal.
Whether or not the out-of-court positive
identification of Roberto as the perpetrator by Eric and Marilou is admissible
and reliable.
YES.
The Court evaluates the out-of-court identification by considering various
factors, including the witnesses' opportunity to view the criminal, their
degree of attention, the accuracy of prior descriptions, the time lapse between
the crime and identification, the level of certainty demonstrated, and the
suggestiveness of the identification procedure. In this case, Eric and
Marilou's identification satisfied these criteria. They had a good view of the
assailant, demonstrated a high degree of attention, and immediately provided a
description. The time lapse between the crime and identification was
reasonable, and the witnesses were certain in their identification without
evidence of suggestiveness.
Roberto's claims of police misconduct, failure to
present paraffin test results, and inconsistencies in eyewitness accounts were
dismissed. The Court emphasized that the positive identification of Roberto by
the witnesses, along with their credibility, prevails over Roberto's alibi and
denial. This case reaffirms the principle that the positive identification of
the accused by credible witnesses, if not tainted by suggestiveness or
procedural flaws, prevails over defenses such as alibi and denial. Eric's
reaction during the incident, inconsistent with his military background, is
considered a natural human response.
The Court affirmed the conviction for the special
complex crime of robbery with homicide, stating that the killing was incidental
to the robbery, and the intent to commit robbery is the primary objective. The
penalty of reclusion perpetua was deemed appropriate, with adjustments made to
the damages awarded in line with prevailing jurisprudence. Roberto is also
directed to return the stolen item or pay its value.
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