Positive Identification and Conspiracy in Murder Cases: Clarifying Witness Credibility
People v. Martin shows how Philippine courts weigh eyewitness identification, alibi, conspiracy, and damages in a murder conviction and appeal.
A murder conviction usually turns on a single question: is the eyewitness believable? In People of the Philippines v. Dean Martin y Sarvida @ Denden and Romeo Tanoan y Macailig, G.R. No. 177571 (September 29, 2008), the Supreme Court affirmed a murder conviction built largely on the testimony of the victim's wife and his fellow jeepney driver — and in doing so restated settled rules on positive identification, delay in reporting, alibi, and conspiracy that continue to guide Philippine criminal cases.
The killing of a jeepney driver
On the evening of April 2,
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