Doubt makes motive material
Motive becomes material only when the evidence is circumstantial or inconclusive and there is some doubt on whether the accused had committed it. It assumes significance only where there is no showing of who the perpetrator of the crime was, or when the identity of the culprit is doubtful.
Resay vs. People, G.R. No. 154502, 27 April 2007: Resayo points out that he had no motive to harm Aguinaldo. He maintains that it was a rumble where the participants acted on their own, with no clear intention of conspiring to hurt or kill a particular person.
Motive is not essential to convict when there is no doubt as to the identity of the culprit. Lack of motive does not preclude conviction when the crime and the participation of the accused in the crime are definitely shown, particularly when we consider that it is a matter of judicial knowledge that persons have killed or committed serious offenses for no reason at all.
People vs. Delos Santos, G.R. No. 135919, 09 May 2003: Appellant argues that since the prosecution witnesses testified that there was no altercation between him and Flores, it follows that no motive to kill can be attributed to him. This is an inconsequential argument. Proof of motive is not indispensable for a conviction, particularly where the accused is positively identified by an eyewitness and his participation is adequately established. In People vs. Galano, we ruled that in the crime of murder, motive is not an element of the offense, it becomes material only when the evidence is circumstantial or inconclusive and there is some doubt on whether the accused had committed it. In the case before us, no such doubt exits as De Leon and Tablate positively identified appellant.
Weighing the evidence of the prosecution vis--vis that of the defense, the scale of justice must tilt in favor of the former. Time and again, we ruled that positive identification, where categorical and consistent and without any showing of ill-motive on the part of the eyewitnesses testifying on the matter, prevails over alibi and denial which, if not substantiated by clear and convincing proof, are negative and self-serving evidence undeserving of weight in law. With marked relevance is the fact that appellant did not present any evidence to show that the prosecution witnesses, in testifying against him, have improper motive.
Lack of motive for committing the crime does not preclude conviction for such crime when the crime and participation of the accused are definitely proved.
Velasco vs. People, G.R. No. 166479, 28 February 2006: Petitioners asseveration that it is unthinkable for him to shoot private complainant because he has no motive to harm, much less kill the latter, he being a total stranger, deserves scant consideration. It must be stressed that motive is a state of (ones) mind which others cannot discern. It is not an element of the crime, and as such does not have to be proved. In fact, lack of motive for committing a crime does not preclude conviction. It is judicial knowledge that persons have been killed or assaulted for no reason at all. Even in the absence of a known motive, the time-honored rule is that motive is not essential to convict when there is no doubt as to the identity of the culprit. Motive assumes significance only where there is no showing of who the perpetrator of the crime was. In the case at bar, since petitioner has been positively identified as the assailant, the lack of motive is no longer of consequence.
Petitioner argues that the testimony of prosecution witness Armando Maramba should not be given weight because the same is biased and incredible on the ground that he is the uncle of the private complainant.
This argument does not inspire belief. The blood relationship of Armando Maramba and private complainant would not render the formers testimony unworthy of belief.On the contrary, relationship could strengthen the witnesses credibility, for it is unnatural for an aggrieved relative to falsely accuse someone other than the actual culprit. Their natural interest in securing the conviction of the guilty would deter them from implicating a person other than the true offender. It is settled that where there is no evidence and nothing to indicate that the principal witnesses for the prosecution were actuated by improper motive, the presumption is that they were not so actuated and their testimonies are entitled to full faith and credit. The weight of the testimony of witnesses is not impaired nor in anyway affected by their relationship to the victim when there is no showing of improper motive on their part. Jurisprudence likewise holds that if an accused had really nothing to do with a crime, it would be against the natural order of events and of human nature, and against the presumption of good faith, that a prosecution witness would falsely testify against him. In the case before us, aside from petitioners claim that he was framed-up, there is nothing in the records that shows that Armando Maramba had ulterior motives in testifying against him. Necessarily, the testimony of Armando Maramba must be given full credit.
