G.R. No. 186528 ; January 26, 2011
People of the Philippines, Plaintiff-Appellee, vs. Hemiano de Jesus and Rodelo Morales, Accused-Appellants.

FACTS

Accused Hemiano de Jesus and Rodelo Morales were charged with Murder before the Regional Trial Court (RTC) of Batangas for the killing of Armando Arasula on July 9, 1992, in Barangay Libato, San Juan, Batangas. The Information alleged they conspired, armed with a small bolo (gulukan), and attacked the victim with treachery, evident premeditation, and abuse of superior strength. The accused were arrested in 2000 and pleaded not guilty. The prosecution presented Santiago Arasula, the victim’s brother, as an eyewitness. He testified that after leaving a birthday party earlier, he heard his brother shout for help, ran to him, and saw the two accused still stabbing the victim as he lay on the ground. The defense presented Rodelo Morales, who claimed he was home cooking at the time, and Hemiano de Jesus, who admitted killing the victim but claimed self-defense, stating the victim attacked him first with a bolo after an argument. The RTC convicted both accused of Murder, sentencing them to Reclusion Perpetua to Death and ordering them to pay damages. The Court of Appeals (CA) upheld the conviction but modified the penalty to Reclusion Perpetua and adjusted the damages awarded.

ISSUE

The primary issue is whether the CA correctly affirmed the conviction of the accused-appellants for Murder, upholding the credibility of the prosecution’s eyewitness and rejecting the defenses of denial and self-defense.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the CA Decision with modifications. The Court found the appeal without merit. It upheld the credibility of eyewitness Santiago Arasula, who testified in a candid and straightforward manner and positively identified the accused, whom he had known for over five years. The Court rejected Hemiano de Jesus’s claim of self-defense, as he failed to prove the essential elements of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. His flight after the incident and failure to report it to the police negated his claim. The Court also rejected Rodelo Morales’s defense of denial, which is inherently weak against positive identification. The crime was qualified by abuse of superior strength, as the two armed accused jointly attacked the drunk and unarmed victim. The penalty of Reclusion Perpetua was affirmed. The awards of damages were modified: Civil Indemnity of PhP50,000, Moral Damages of PhP50,000, and Temperate Damages of PhP25,000 were sustained. Additionally, Exemplary Damages of PhP30,000 were awarded due to the presence of the qualifying aggravating circumstance of abuse of superior strength. All damages shall earn interest at 6% per annum from the finality of the judgment until fully paid.