Ingal vs. People.pdf - 2/7/2021 SUPREME COURT REPORTS...

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2/7/2021SUPREME COURT REPORTS ANNOTATED VOLUME 5471/26G.R. No. 173282.March 4, 2008.*JOSE INGALySANTOS, petitioner,vs.PEOPLE OF THEPHILIPPINES, respondent.CriminalLaw;Murder;Evidence;Witnesses;Initialreluctance to volunteer information regarding a crime due to fearof reprisal is common enough that it has been judicially declaredas not affecting a witness’ credibility.—The statement of thedefense that Mrs. Bona waited for seven years after divulgingwhat she knew about the stabbing incident is awry. After theincident, Mrs. Bona immediately gave her statement to the policethat petitioner was the one who stabbed the victim. This isevidenced by the Advance Report dated 3 March 1987 prepared byPFC Benjamin Boco. It is not true that she waited for seven yearsbefore revealing what she knew. What she did not immediatelygive to the police was her written statement under oath, becauseshe was fearful that something bad might happen to her becausethe suspect was still at large. She explained she would only giveher written statement when the suspect was apprehended,because the crime was a grave offense. This was what she didonce petitioner was arrested and jailed. She cannot be faulted fordoing what she did. Fear of reprisal and the natural reluctance ofa witness to get involved in a criminal case are sufficientexplanations for a witness’ delay in reporting a crime to theauthorities. Initial reluctance to volunteer information regardinga crime due to fear of reprisal is common enough that it has beenjudicially declared as not affecting a witness’ credibility. The factthat Mrs. Bona did not right away submit a written statement tothe police was natural and within the bounds of expected humanbehavior. Her action revealed a spontaneous and natural reactionof a person who had yet to fully comprehend a shocking andtraumatic event.Same;Same;Same;Same;Settledistherulethatinconsistencies on minor and trivial matters only serve tostrengthen rather than weaken the credibility of witnesses, for theyerase the suspicion of rehearsed testimony.—The defense pointsoutthatMrs.BonacontradictedherstatementinherSinumpaang Salaysaythat she saw petitioner while she wasbeing investigated in the WPD, but in her2/7/2021SUPREME COURT REPORTS ANNOTATED VOLUME 5472/26_______________*THIRD DIVISION.633VOL. 547, MARCH 4, 2008633Ingal vs. Peopletestimony in court she said she had not seen him in the WPD. Asto Mrs. Tan, the defense claims that she did not see the petitionerwhile her statement was being taken by the police which iscontrary to what was stated in herSinumpaang Salaysaythatshe saw petitioner while she was giving her statement. We findthese inconsistencies to be too trivial to diminish the credibility ofthese two witnesses. From their testimonies in court, it is evidentthat they saw petitioner in the police station when he was

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Term
Spring
Professor
law
Tags
Supreme Court of the United States, Appellate court, Mmes Aida Bona

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