GR 93055; (January, 1992) (Digest)
G.R. Nos. 93055-56. January 24, 1992. THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROLDAN MANCIO y SALVERON, ROLANDO C. YERO, EDGAR DAVID, RORONG ESTRERA and RICHARD DOE, accused-appellants.
FACTS
Accused-appellants Roldan Mancio and Rolando Yero, along with three others at large, were charged with Murder and Attempted Murder for the killing of Andrew Angelo and the hacking of Erolando Toledo. The prosecution evidence established that in the early morning of February 13, 1983, Angelo, accompanied by Toledo and another, was confronted by a group of five men on a street in Bagong Silang, Caloocan City. Angelo recognized Mancio, greeting him with “Pareng Roldan, ikaw pala.” Mancio immediately held Angelo by the nape and stabbed him with a long knife. Simultaneously, Yero hacked Toledo on the face with a bolo. The assailants then collectively attacked the fallen Angelo with a bolo, balisong, and lead pipe before fleeing.
The gravely wounded Angelo was transported between hospitals. Conscious of his impending death, he gave a dying declaration to a priest and his mother, specifically naming Mancio and Yero, their long-time neighbors, as among his assailants. He died on February 16, 1983. The defense consisted of alibis: Mancio claimed he was at a hospital accompanying another victim, while Yero asserted he was asleep at home.
ISSUE
Whether the trial court erred in convicting the accused-appellants based on the prosecution’s evidence and in rejecting their defenses.
RULING
The Supreme Court affirmed the conviction. The positive identification of the appellants by multiple eyewitnesses, including the victim Toledo who was attacked at close range, prevailed over their weak alibis. The Court found it was not physically impossible for the appellants to have been at the crime scene. The testimonies of the witnesses were deemed credible, straightforward, and without ill motive, especially considering Mancio was a barangay official and both were longtime neighbors of the victims.
The dying declaration of Angelo, made under a consciousness of impending death and explicitly identifying the appellants, was admissible and carried significant weight as evidence of the circumstances of his death. The Court reiterated the doctrine of according great respect to the trial court’s factual findings and credibility assessments, as it is in the best position to observe the witnesses. Finding no reason to overturn these findings, the appealed decision was affirmed in toto.