GR 247907; (December, 2020) (Digest)
G.R. No. 247907 , December 02, 2020
People of the Philippines, Plaintiff-Appellee, vs. Antonio Ansus, Accused-Appellant.
FACTS
On August 15, 2011, Antonio Olitan, Jr. was killed in Barangay Pandan, Castilla, Sorsogon. The prosecution’s principal witness, Myrna Olitan (the victim’s wife), testified that after stones were thrown at their roof, she and her husband went outside and saw accused-appellant Antonio Ansus about 12 meters away. As they approached him to confront him, Ansus suddenly struck Olitan on the back of the neck with a crowbar, causing Olitan to fall. Myrna, terrified, retreated inside her house. Another alleged eyewitness, Erlindo Buatis, claimed he saw the attack from about four and a half meters away while on an errand. The defense presented a different version, with Ansus claiming he was inside his house and heard a commotion, only to find Olitan already wounded, and suggested the killing was done by a certain “Jun-Jun” who had a prior altercation with the victim.
ISSUE
The core issue is whether the guilt of accused-appellant Antonio Ansus for the crime of Murder was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court found the testimonies of prosecution witnesses Myrna Olitan and Erlindo Buatis credible and consistent on material points, establishing that Ansus was the assailant. The defense of denial and alibi proffered by Ansus was inherently weak and could not prevail over the positive identification by credible witnesses. The Court meticulously addressed alleged inconsistencies in the witnesses’ accounts, such as the exact positioning of the victim and the timing of their reports to authorities, ruling these were minor and did not detract from the core narrative of the crime. The Court held that such minor lapses may even bolster credibility, as they indicate unrehearsed testimony.
Regarding the qualifying circumstance of treachery, the Court agreed with the lower courts that it was present. The attack was sudden and deliberate, employing a crowbar to strike the unarmed victim from behind on a vital part of the body, ensuring the execution of the crime without risk to the assailant. This method of attack deprived the victim of any opportunity to defend himself. The Court modified the awarded damages in accordance with prevailing jurisprudence but sustained the penalty of reclusion perpetua, as the prosecution successfully proved all elements of Murder qualified by treachery beyond reasonable doubt.