PEOPLE vs.

GLORIA UMALI y AMADO AND SUZETH UMALI y AMADO

G.R. No. 8445 February 4, 1991
MEDIALDEA, J.:
Topic: Witness
Facts:
Pierre Pangan, a minor was investigated by Pat. Felino Noguerra for drug dependency and for an alleged crime of
robbery. In the course of the investigation, the policemen discovered that Pierre Pangan was capable of committing
such only if under the influence of drug. Leopoldo Pangan, father of the minor asked the police investigators if
something could be done to determine the source of the marijuana which has not only socially affected his son, but
other minors in the community like the case of Francisco Manalo, who was likewise investigated by operatives of the
Tiaong, Quezon Police Department and for which a case for violation of the Dangerous Drug Act was filed against
him, and other cases. Manalo although a detention prisoner was touched by the appeal made to him by the
policeman and agreed to help in the identification of the source of the marijuana. In return he asked the policeman
to help him in some cases pending against him.

With the consent of Francisco Manalo, Pfc. Sarmiento, Chief of the Investigation Division gave him four (4) marked
P5.00 bills to buy marijuana from sources known to him. Few minutes there after, Manalo returned with two (2) foils
of dried marijuana which lie allegedly bought from the accused Gloria Umali. Thereafter, he was asked by the police
investigators to give a statement on the manner and circumstances
Issue/s:
Whether or not Manalo should be disqualified as a witness
Ruling/s:
NO. Time and again, it is stressed that this Court is enjoined from casually modifying or rejecting the trial court's
factual findings. Such factual findings, particularly the trial judge's assessment of the credibility of the testimony of
the witnesses are accorded with great respect on appeal for the trial judge enjoys the advantage of directly and at
first hand observing and examining the testimonial and other proofs as they are presented at the trial and is
therefore better situated to form accurate impressions and conclusions on the basis thereof. The findings of the trial
court are entitled to great weight, and should not be disturbed on appeal unless it is shown that the trial court had
overlooked certain facts of weight and importance, it being acknowledged that the court below, having seen and
heard the witnesses during the trial, is in a better position to evaluate their testimonies. Hence, in the absence of
any showing that the trial court had overlooked certain substantial facts, said factual findings are entitled to great
weight, and indeed are binding even on this Court.

Rule 130, Section 20 of the Revised Rules of Court provides that:

Except as provided in the next succeeding section, all persons who can perceive, and perceiving can make
known their perception to others may be witnesses.

Religious or political belief, interest in the outcome of the case, or conviction of a crime unless otherwise
provided by law, shall not be a ground for disqualification.

The phrase "conviction of a crime unless otherwise provided by law" takes into account Article 821 of the Civil Code
which states that persons 91 convicted of falsification of a document, perjury or false testimony" are disqualified
from being witnesses to a will."

Since the witness Francisco Manalo is not convicted of any of the above-mentioned crimes to disqualify him as a
witness and this case does not involve the probate of a will, We rule that the fact that said witness is facing several
criminal charges when he testified did not in any way disqualify him as a witness. The testimony of a witness should
be given full faith and credit, in the absence of evidence that he was actuated by improper motive, in the absence of
any evidence that witness Francisco Manalo was actuated by improper motive, his testimony must be accorded full
credence.

Appellant's contention that she was a victim of a "frame-up" is devoid of merit.1âwphi1 "Courts must be vigilant. A
handy defense in such cases is that it is a frame-up and that the police attempted to extort from the accused.
Extreme caution must be exercised in appreciating such defense. It is just as easy to concoct as a frame-up. At all
times the police, the prosecution and the Courts must be always on guard against these hazards in the
administration of criminal justice."