People v. Castayeda (G.R. No. 114972; January 24, 1996)
FACTS:
ISSUE:
RULING:
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SYLLABUS
1. REMEDIAL LAW; EVIDENCE; SUPPRESSION OF EVIDENCE; DOES NOT APPLY WHEN THE TESTIMONY OF THE WITNESS NOT PRODUCED WOULD ONLY BE CORROBORATIVE. - The rule on suppression of evidence cannot be invoked by accused-appellant where the same evidence is available to him. In the case at bar, accused-appellant could have subpoenaed the barangay officials who allegedly heard the description of the culprit given by the private complainant. These barangay officials were not under the control of private complainant, a lowly housewife in barangay Sta. Maria, Concepcion, Tarlac. It is far fetched to accuse her and the prosecution of suppressing their testimonies. Moreover, their testimonies could only be corroborative. In People v. Lorenzo, G.R. No. 110107, January 26, 1995, 240 SCRA 624, we held that the presumption laid down in Section 5 (e), Rule 131 of the Rules of Court that evidence willfully suppressed would be adverse if produced does not apply when the testimony of the witness not produced would only be corroborative.
2. ID.; ID.; GUILT OF THE ACCUSED; RETURN TO THE SITUS OF THE CRIME DOES NOT INDICATE INNOCENCE. - Although flight from the scene is an indication of guilt, the act of returning to the situs of the crime does not a converso indicate innocence. It is no longer strange for smart criminals to return to the scene of the crime to stunt suspicion. As this Court observed in People vs. Ocampo, G.R. No. 80262, September 1, 1993, 226 SCRA 1 the fact that this form of reverse psychology does not happen as often as flight, does not mean that it can never take place.
