GR 101367; (March, 1992) (Digest)
G.R. No. 101367 March 23, 1992
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ELMO CATUA, PETER CATUA, and RUBEN CATUA, defendants-appellants.
FACTS
On February 21, 1986, spouses Fernando Bautista and Marina Bautista were planting corn on their farm in Calyawa, Kapalong, Davao, with their children Tirso (14) and Catalina (12). Around 10:00 a.m., five persons, including the appellants (Elmo, Peter, and Ruben Catua), appeared and shot the spouses. Tirso and Catalina, who were about 20 meters away, witnessed the shooting and identified the appellants, whom they had known since childhood. Felix Remitar, working on a nearby elevated farm, also heard the gunfire, looked down, saw the shooting, and recognized the Catua brothers as friends. The victims died from their wounds. The appellants denied involvement and presented alibis: Ruben claimed he was in Asuncion, Davao, and had been hospitalized for malaria months later; Elmo alleged he was cutting grass in Suwaon, Kapalong; and Peter asserted he was at home in Monte Dujali, Kapalong, with his sick child. The trial court convicted them of double murder and sentenced them to an indeterminate penalty. The Court of Appeals certified the case to the Supreme Court due to the imposition of two penalties of reclusion perpetua per appellant.
ISSUE
1. Whether the appellants’ guilt for the crime of double murder was proven beyond reasonable doubt.
2. Whether the qualifying circumstance of treachery was properly established.
RULING
The Supreme Court affirmed the conviction. The appellants’ guilt was proven beyond reasonable doubt through the positive identification by eyewitnesses Tirso Bautista and Felix Remitar, corroborated by Jose Tunga. Their alibis were rejected as weak and inherently unreliable, especially when juxtaposed with clear, positive testimonies. The Court found it was not physically impossible for them to be at the crime scene, given the accessibility of the locations by public transport. Treachery was established, as the appellants, armed with rifles and shotguns, suddenly fired upon the unarmed victims without warning, leaving them no opportunity for defense or escape. Conspiracy was inferred from their concerted actions before, during, and after the shooting. The penalty for murder is reclusion temporal maximum to death; with no aggravating or mitigating circumstances, the medium period of reclusion perpetua was applied. Each appellant was sentenced to two penalties of reclusion perpetua for the two murders. The civil indemnity was increased from P60,000 to P100,000 (P50,000 per victim).