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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: 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. Juan Sanchez
kicked them. They posed for a fight but Joey Guiyab said You try and you will see while
holding a knife. Madriaga hit Sanchez with a stone, and so Guiyab chased him. According to
Madriaga, Guiyab failed to catch him so Guiyab instead attacked Bacani, stabbing him once on
the right chest. Bacani was brought to the hospital and died a day after. SP04 Romeo Tumolava
also testified that he saw Guiyab near the Community Center at the night of the incident.

Defense Evidence: According to Guiyab, he was not at Tumauini Cultural and Sports
Center at the time the incident happened. He was farming until 5:00 p.m. at Sitio Bayabo,
Camasi, and slept at around 9:00 p.m. in their house. This was corroborated by his neighbor
Domingo Gumaru, and his parents, Silvino and Vicenta Guiyab.

Both the TC and CA found Guiyab guilty. Guiyab appealed to the SC, alleging his
identification was tainted, since his name was only fed to the witness Madriaga.

Issue: WON 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, he 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.

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