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Monday, April 29, 2024

Motive in criminal cases (1)

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The Supreme Court said as long as the testimony of the witness is coherent and intrinsically believable as a whole, discrepancies in minor details and collateral matters do not affect the veracity… of the witnesses’ declarations

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Motive is something that causes a person to act (Merriam-Webster Dictionary).

“Motive becomes relevant and its absence may assume determinative significance when the accused has not been positively identified, and proof thereof becomes essential only when the evidence of the commission of the crime is purely circumstantial or is inconclusive” (People of the Philippines v. Sarino, et al., G.R. 94992-93, April 7, 1993).

In the case of U.S. v. Go Foo Suy, the Supreme Court declared the “motive of committing the crime was powerful; the incriminating evidence is strong; and suspicion rests upon the exculpatory evidence submitted by the defense in many places.”

“The appellant Go Foo Suy was offered as a witness in his own behalf by counsel, but upon being refused a Chinese interpreter, counsel declined to permit him to testify” (G.R. 8217, Sept. 5, 1913).

However, “Go Foo Suy himself testified he had been resident of Cebu 17 or 18 years, and the court observed the witness was able to testify in the local dialect if he had wished to do so.

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“[T]he court stated an interpreter would translate his statements whenever he found any difficulty in making them… [hence], there was [no] prejudicial error in not allowing the appellant an interpreter” (G.R. 8217, Sept 5, 1913).

Appellants Go Foo Suy and Go Jancho were the owners of the merchandise and the beneficiaries of the insurance.

“[T]hat their business operations… just prior to the fire had resulted in a loss of at least P4,000… [and]… had been conducting their business at a loss for nearly 18 months… meant they would receive about twice the value of their stock of goods and thus convert a losing investment into a profitable one” (G.R. 8217, Sept 5, 1913).

In another case, there was an absence of motive in the testimony of a witness against an accused.

The Supreme Court said “the records are bereft of any showing that Victoria’s testimony was inspired by ill motive or was attended by bad faith” (People of the Phiippines v. Manzano, et al., G.R. 217974, March 5, 2018).

“Jurisprudence holds that when there is no evidence to show any improper motive on the part of the witness to testify falsely against the accused or to pervert the truth, the logical conclusion is no such motive exists, and that the former’s testimony is worthy of full faith and credit” (G.R. 217974, March 5, 2018).

The Supreme Court further declared “the accused-appellant failed to proffer any convincing and material variations in the testimony of Victoria that would warrant the Court to reverse the RTC’s finding as to her credibility.

“It is settled in this jurisdiction that as long as the testimony of the witness is coherent and intrinsically believable as a whole, discrepancies in minor details and collateral matters do not affect the veracity… of the witnesses’ declarations” (G.R. 217974, March 5, 2018).

In yet another case, “[t]he witnesses who testified against appellant Macatangay were unmistakably biased. Florentino Estiron was father of the deceased.

“And even if we give credence to his statement respecting Macatangay’s motive, in the absence of adequate proof establishing complicity, still Macatangay cannot be convicted” (People of the Philippines v. Macatangay, et al., G.R. L-12942, Feb 29, 1960).

“Mere proof of motive, no matter how strong, is not sufficient to support a conviction if there is no other reliable evidence from which it may be reasonably deduced that the accused was the malefactor” (G.R. L-12942, Feb 29, 1960).

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