G.R. No. 108183 -85 August 21, 1997
People of the Philippines vs. Dione Palomar, et al.

FACTS

The accused-appellants, along with several others, were charged with multiple murder, frustrated murder, and attempted homicide arising from a violent incident on April 30, 1985, in Manjuyod, Negros Oriental. The prosecution alleged that the accused, acting in concert, attacked a group of victims with stones, an air rifle, bolos, and spears, resulting in the deaths of Pedro dela Peña, Gaudencio Cadiente, Jesper dela Peña, and Fernando dela Peña. Susan Cadiente survived hacking injuries, and Aniano dela Peña sustained wounds from the attack. The cases were consolidated for trial. The prosecution primarily relied on the testimonies of eyewitnesses Aniano dela Peña and Susan Cadiente. The trial court convicted the appellants, sentencing them to reclusion perpetua for multiple murder and imposing penalties for the other crimes.

ISSUE

The core issue is whether the trial court erred in convicting the accused-appellants based on the credibility of the prosecution witnesses’ testimonies, despite alleged inconsistencies, and in its application of penalties for the complex crime of multiple murder.

RULING

The Supreme Court affirmed the convictions but modified the penalties. The Court upheld the trial court’s assessment of witness credibility, reiterating that minor inconsistencies in testimonies strengthen rather than weaken credibility, as they indicate unrehearsed narration. The Court found no reason to overturn the factual findings, emphasizing the trial court’s superior position to observe witness demeanor. On the legal issue, the Court corrected the penalty imposed for multiple murder. The trial court erroneously imposed a single penalty of reclusion perpetua. The Court clarified that under Article 48 of the Revised Penal Code, when a single act constitutes multiple crimes (as in this case where one assault killed four persons), the penalty for the most serious crime (murder) should be imposed in its maximum period. Since murder is punishable by reclusion temporal in its maximum period to death, and there were no aggravating or mitigating circumstances, the proper penalty is reclusion perpetua for each murder. However, applying the Indeterminate Sentence Law, the penalty for the complex crime is death, but due to the prohibition thereof at the time of the crime, it is reduced to reclusion perpetua. The Court thus imposed reclusion perpetua for each of the four murders, to be served simultaneously. The awards of civil indemnity were also affirmed.