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PEOPLE v. CARLITO MATEO Y PATAWID

This case has been cited 9 times or more.

2015-03-11
DEL CASTILLO, J.
Further, the alleged inconsistency in P01 Sta. Maria's testimony pertaining to petitioner's actual position when he was said to be seen holding the sachet of shabu is too trivial and irrelevant to the elements of the crime. This Court has ruled that "inconsistencies in the testimonies of witnesses which refer to minor and insignificant details cannot destroy their credibility. Such minor inconsistencies even guarantee truthfulness and candor."[22]
2013-07-17
PEREZ, J.
In the same vein, we are not persuaded by the appellant's defense of denial. Well entrenched is the rule that the defense of denial can easily be overcome by a positive identification that is categorical, consistent and untainted by any ill motive on the part of the eyewitnesses testifying on the matter. Nothing is more settled in criminal law jurisprudence than that denial and alibi cannot prevail over the positive and categorical testimony of the witness.[17] As aptly cited in the case of People of the Phils. v. Carlito Mateo y Patawid,[18] the defense of denial cannot surmount the positive and affirmative testimony offered by the prosecution. It is self-serving deserving no weight in law. Alibi, on the other hand, is viewed with suspicion and received with caution, because it can easily be fabricated.[19] For alibi to prosper, appellant must prove not only that he was at some other place when the crime was committed but that it was physically impossible for him to be at the locus criminis at the time of its commission.[20]
2010-04-14
NACHURA, J.
We would like to stress that non-compliance with the requirements set forth in R.A. No. 9165 on the custody and disposition of confiscated or seized drugs, under justifiable grounds, shall not render void and invalid the seizures and custody of said items as long as the integrity and evidentiary value of the seized items are properly preserved by the apprehending officers.[10]
2010-02-05
DEL CASTILLO, J.
In the present case, all the elements of the crime have been sufficiently established. Prosecution witness PO1 Inopia consistently testified that a buy-bust operation took place. As the poseur-buyer, he positively identified the appellant as the seller of a sealed sachet containing a white crystalline substance for a sum of P500.00. The sachet was confiscated and marked with initials "NDA" and taken to the crime laboratory for examination, where a chemical analysis on the contents thereof confirmed that the same are indeed methylamphetamine hydrochloride or "shabu". The sachet containing said dangerous drug was positively identified by PO1 Inopia during the trial as the very sachet with white crystalline substance sold and delivered to him by the appellant. Thus, appellant's defense of denial is unavailing. It has been consistently held that mere denial cannot prevail over the positive testimony of a prosecution witness. A defense of denial which is unsupported and unsubstantiated by clear and convincing evidence becomes negative and self-serving, deserving no weight in law, and cannot be given greater evidentiary value over convincing, straightforward and probable testimony on affirmative matters.[11]
2009-10-12
VELASCO JR., J.
What is more, the allegation of material inconsistencies involves a question of fact which generally cannot be raised. We will not disturb the findings of the trial court in assessing the credibility of the witnesses, unless some facts or circumstances of weight and influence have been overlooked or the significance of which has been misinterpreted by the trial court.[16] This is so because of the judicial experience that trial courts have; they are in a better position to decide the question, having heard the witnesses themselves and observed their deportment and manner of testifying during the trial. They can, thus, more easily detect whether a witness is telling the truth or not.[17] All the more do we apply this rule when the trial courts' findings are sustained by the appellate court.[18]
2009-08-24
VELASCO JR., J.
The positive and categorical testimony of SJO2 Sarino satisfactorily proves Macabare's guilt of illegal possession of shabu. We agree with the CA when it ruled that Macabare's mere denial cannot outweigh circumstantial evidence clearly establishing his participation in the crime charged. It is well-settled that positive declarations of a prosecution witness prevail over the bare denials of an accused.[20] The evidence for the prosecution was found by both the trial and appellate courts to be sufficient and credible while Macabare's defense of denial was weak, self-serving, speculative, and uncorroborated. An accused can only be exonerated if the prosecution fails to meet the quantum of proof required to overcome the constitutional presumption of innocence.[21] We find that the prosecution has met this quantum of proof in the instant case.
2009-06-22
NACHURA, J.
In People v. Mateo[28] and People v. Larry Lopez,[29] the Court held that the period of imprisonment imposed on the accused should not be a straight penalty, but should be an indeterminate penalty. Thus, the trial court erred in imposing, and the CA in affirming, the straight penalty of imprisonment of twelve (12) years and one (1) day.
2009-02-27
NACHURA, J.
As to the appellants' defense which is based mainly on denial and alibi, nothing is more settled in criminal law jurisprudence than that denial and alibi cannot prevail over the positive and categorical testimony of the witness.[21] In People of the Phils. v. Carlito Mateo y Patawid,[22] we had occasion to state:Accused-appellant's bare-faced defense of denial cannot surmount the positive and affirmative testimony offered by the prosecution. x x x. A defense of denial which is unsupported and unsubstantiated by clear and convincing evidence becomes negative and self-serving, deserving no weight in law, and cannot be given greater evidentiary value over convincing, straightforward and probable testimony on affirmative matters. x x x.
2008-11-14
CARPIO, J.
While appellant is also guilty beyond reasonable doubt of violation of Section 11, Article II of RA 9165, the Court modifies the penalty imposed in Criminal Case No. 3189 for illegal possession of marijuana. In People v. Mateo,[16] the Court held that the period of imprisonment imposed on the accused should not be a straight penalty, but should be an indeterminate penalty. Thus, the trial court erred in imposing the straight penalty of imprisonment of fourteen (14) years.