GR L 31682; (July, 1982) (Digest)
G.R. No. L-31682 July 20, 1982
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VIRGILIO NACUSPAG, PABLO NACUSPAG, ERNESTO SARADOLLA and ARISTEDES SALAZAR, defendants-appellants.
FACTS
The case originated from a murder charge against four accused for the killing of Iniego Nala during a reunion in Madalag, Aklan, on September 7, 1966. The information alleged conspiracy, evident premeditation, treachery, and abuse of superior strength. After trial, the court found Pablo Nacuspag guilty as a principal of murder and sentenced him to reclusion perpetua. His co-accused were convicted as accomplices. Virgilio Nacuspag, Ernesto Saradolla, and Aristedes Salazar subsequently withdrew their appeals, leaving Pablo Nacuspag as the sole appellant.
The prosecution evidence established that the uninvited accused, all armed with knives, attended the celebration. Without any provocation, Virgilio Nacuspag fist struck the victim, followed by Pablo Nacuspag. Aristedes Salazar then held the victim from behind, after which Pablo Nacuspag stabbed Iniego Nala on the left chest, causing his death. The defense claimed self-defense, contending the victim had a bolo. The trial court rejected this, crediting the prosecution witnesses’ account that the attack was sudden and unprovoked.
ISSUE
The core issue is whether the trial court erred in convicting appellant Pablo Nacuspag of murder, specifically in rejecting his claim of self-defense and in giving credence to the prosecution’s evidence.
RULING
The Supreme Court affirmed the conviction. The ruling hinges on the settled doctrine of appellate deference to the trial court’s factual findings and credibility assessments. The Court emphasized that the trial judge is in the optimal position to observe witness demeanor, sincerity, and manner of testifying. Absent a clear showing that the trial court overlooked material facts or arbitrarily disregarded evidence, its factual conclusions are binding on review.
The Court found no such oversight here. The prosecution evidence, summarized from witness testimonies, clearly established a coordinated, sudden, and unprovoked attack by the accused against the victim. The claim of self-defense was properly rejected as the evidence showed the victim was holding a banjo, not a bolo, at the moment of the initial assault and was thereafter restrained, negating any unlawful aggression on his part. The qualifying circumstance of treachery was present, as the mode of attack ensured the victim had no opportunity to defend himself. Consequently, the judgment finding Pablo Nacuspag guilty as a principal of murder and imposing reclusion perpetua was affirmed in toto.