G.R. No. 177223 ; November 28, 2007
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. CASTOR BATIN, Accused-Appellant.

FACTS

Accused-appellant Castor Batin and his son, Neil Batin, were charged with Murder for the shooting death of Eugenio Refugio on October 21, 1994, in Quezon City. The prosecution evidence established that on the afternoon of the incident, Castor was seen angrily muttering and challenging people to a fight near the victim’s residence. The victim’s wife, Josephine Refugio, witnessed Castor approach his son Neil, who retrieved a gun from a parked car. After a brief exchange where Castor initially took and then returned the firearm to Neil, Castor was heard ordering, “Sige, banatan mo na.” Neil then aimed and fired twice at Eugenio, who was leaning against a mango tree with his wife facing him. Eugenio died from the gunshot wound.
The Regional Trial Court convicted both father and son of Murder qualified by treachery. On appeal, the Court of Appeals affirmed the conviction of Castor Batin but acquitted Neil Batin on reasonable doubt, noting the gunman’s identity was not proven with moral certainty. The appellate court, however, sustained Castor’s liability as a principal by inducement. Castor appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant Castor Batin’s conviction for the crime of Murder.

RULING

The Supreme Court affirmed the conviction. The Court upheld the factual findings of the lower courts, emphasizing that the assessment of witness credibility is best undertaken by the trial court. The testimony of Josephine Refugio, corroborated by other eyewitnesses, was found credible and sufficient to establish Castor’s criminal liability.
On the legal logic, the Court ruled that Castor Batin is liable as a principal by inducement under Article 17 of the Revised Penal Code. The evidence clearly showed he directly ordered and instigated the killing by commanding his son, “Sige, banatan mo na,” which directly influenced the commission of the crime. This verbal inducement was made with the determination to commit the offense. The qualifying circumstance of treachery was correctly appreciated because the attack was sudden and unexpected, ensuring the victim had no opportunity to defend himself. The victim was unarmed and in a non-confrontational posture, making the mode of attack deliberate and efficient for the assailant’s safety from any retaliation.
The Court modified the damages awarded, reducing moral damages to Fifty Thousand Pesos (₱50,000.00) in line with prevailing jurisprudence, while affirming the award of civil indemnity and loss of earning capacity. The decision of the Court of Appeals was thus affirmed with modification.