PEOPLE OF THE PHILIPPINES V.

ELEZER GALAPIN AND ERNEST BIERA

G.R. NO. 124215, JULY 31, 1998

FACTS: The victim, Roberto Pillora, had an argument with Elezer Galapin and Ernesto
Biera, brother-in-law of Galapin inside a store. When he stood up to leave, his hands
were held by Ernesto and then pulled his jacket down. While in that position, Galapin
stabbed Pillora at the chest with a fan knife who later died. Galapin and Biera were
charged with murder. Galapin voluntarily surrendered and claimed self-defense alleging
that Pillora pulled a fan knife though still closed and they grappled for possession
thereof, and when Galapin got hold of the knife he stabbed Pillora. Biera interposed
alibi. However, both Galapin and Biera were positively identified by witness Mely
Ardeña, an operator of a “carinderia”, and Regemer Gutierrez, a nephew of the victim.
The trial court, giving full faith on the testimonies of the prosecution witnesses, rendered
judgment of conviction, and sentenced them to life imprisonment.

ISSUE: Whether the testimony of Guttierez should be considered as biased on

account that Pillora is Guitterez’ uncle

RULING: No.
Relationship per se does not give rise to a presumption of bias or ulterior motive, nor
does it ipso facto impair the credibility or tarnish the testimony of a witness. The Court
held that the natural interest of witnesses who are relatives of the victim in securing the
conviction of the guilty would deter them from implicating persons other than the culprits
for, otherwise, the latter would thereby go unpunished. A witness' relationship to a victim
of a crime, far from rendering his testimony biased, even makes it more credible as it
would be unnatural for a relative who is interested in vindicating the crime to accuse
somebody other than the real culprit. The Court further ruled that there is absolutely
nothing in this jurisdiction which disqualifies a person from testifying in a criminal case in
which a relative is involved, if the former was really at the scene of the crime and
witnessed the execution of the criminal act.