GUIYAB v.

PEOPLE
October 20, 2005
Quisumbing, J.

Short version: Joey Guiyab was convicted of homicide by the TC and CA based on the testimony of witness Joseph
Madriaga. Madriaga testified that Guiyab and a Juan Sanchez attacked him and his companion Rafael Bacani, the victim,
with a knife. SC believed Madriagas positive identification of Guiyab.

FACTS
Prosecution Evidence:
Testimony of witness Madriaga
On December 12, 1992 at around 9:00 p.m., victim Rafael Bacani and witness Joseph Madriaga
were in front of the Community Center in Tumauini. A certain Juan Sanchez approached and
kicked them.

They posed for a fight but Joey Guiyab said Pureban nu ta inanna nu, or You try and you will
see while brandishing a knife.

Joseph hit Sanchez with a stone, and so Guiyab chased him. According to Joseph, Guiyab failed
to catch him so Guiyab instead attacked Rafael who was following them behind, stabbing him
once on the right chest. Rafael was brought to the hospital and died a day after.

Testimony of Dr Cruz, resident physician Isabela Provincial Hospital

Victim Rafael died of cardiorespiratory arrest, the antecedent cause of which is hypovolemic
shock and the underlying cause is the stab wound at the anterior chest.

Testimony of Visitacion Matias, mother of Rafael

On danages

Testimony of Domingo Gumaru, accuseds neighbor

Charge
Petitioner Joey Guiyab was charged with Homicide before the Regional Trial Court of Cabagan.

Defense
SP04 Romeo Tumolava, kumpadre of accuseds parents
That he saw Guiyab near the Community Center at the night of the incident.

RTC/CA
Found Guiyab guilty.

Defense:
That the real identity of the assailant was not fully established by the prosecution since the lone eyewitness
(Joseph Madriaga) learned the name of the petitioner only after it was fed to him by Police Officer Armando
Lugo.

Thus the identification of the accused was tainted with conjecture and speculation.

Issue: WON the the accused was adequately identified - YES (or, the identification of the petitioner was tainted with
conjecture and speculation NO)

Held: The SC found Madriagas identification of Joey Guiyab credible.

Even if he did not know the name of Guiyab prior to the incident, Madriaga was able to identify him in open court when
he was asked to point out the person responsible for the stabbing.

Besides, Madriaga maintained that although he did not know Guiyab by name, he knew him by his face as part of the
community.
There is nothing in law or jurisprudence which requires, as a condition sine qua non, that, for a positive
identification of a felon by a prosecution witness to be good, the witness must first know the former personally.

The witness need not have to know the name of the accused for so long as he recognizes his face.

Knowing the identity of an accused is different from knowing his name.

Hence, the positive identification of the malefactor should not be disregarded just because his name was
supplied to the eyewitness.

The weight of the eyewitness account is premised on the fact that the said witness saw the accused commit the
crime, and not because he knew his name.

DISPOSITIVE: WHEREFORE, the petition is DENIED. The Decision dated September 27, 2001 and the Resolution dated
February 26, 2002 of the Court of Appeals in CA-G.R. CR No. 23703, which sustained the judgment of the Regional Trial
Court, finding petitioner JOEY GUIYAB guilty of Homicide and sentencing him to suffer an indeterminate penalty of
prision mayor medium to reclusion temporal minimum or from eight (8) years and one (1) day to fourteen (14) years and
eight (8) months, and to PAY the heirs of Rafael Bacani P50,000.00 as death indemnity, plus P30,000.00 for actual
damages and P18,000.00 for funeral expenses, without subsidiary imprisonment in case of insolvency, are AFFIRMED.
Costs de oficio.
SO ORDERED.