G.R. No. 101257 September 23, 1993
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GREGORIO BRIONES, JR., JOSE ESTRIBER, FRANCISCO RUFINO, AND TEODORICA MENDIONA, accused-appellants.

FACTS

Accused-appellants Gregorio Briones, Jr., Jose Estriber, Francisco Rufino, and Teodorica Mendiona were charged with Murder in the Regional Trial Court. They were convicted, with Briones, Estriber, and Rufino found guilty as principals and Mendiona as an accomplice. The Court of Appeals affirmed the conviction but modified the penalty to reclusion perpetua for all appellants and increased the indemnity, subsequently certifying the case to the Supreme Court. Teodorica Mendiona withdrew her appeal. The prosecution evidence established that on August 15, 1987, after a drinking session, the victim Wenceslao Camposano and his son were leaving when eyewitness Eugenio Malquisto saw Mendiona focus a flashlight on Camposano while Briones, Estriber, and Rufino hacked him with bolos. The victim died from multiple stab wounds. The appellants presented a different version, with Briones claiming self-defense, alleging the victim attacked him with a coconut frond and later a bolo, and the other appellants denying participation, stating they were delivering fish and fled when trouble started.

ISSUE

1. Whether the Court of Appeals erred in giving weight to the allegedly inconsistent testimonies of prosecution witnesses Eugenio Malquisto and Francisca Nove.
2. Whether the Court of Appeals erred in not acquitting the accused-appellants on the ground of reasonable doubt.
3. Whether the Court of Appeals erred in not finding that accused Gregorio Briones, Jr. acted in self-defense.

RULING

The Supreme Court affirmed the decision of the trial court as modified by the Court of Appeals.
1. The alleged inconsistencies in the testimonies of Malquisto and Nove pertained to minor details (types of bolos used, nature of blows, where the flashlight was focused, and who brought the victim to the hospital) and did not affect their credibility on the essential fact that appellants attacked the victim. Inconsistencies on minor matters are natural and do not diminish credibility when witnesses are consistent on the principal occurrence and the identification of the assailants.
2. The claim of reasonable doubt was without merit. The testimonies of the eyewitnesses were credible and consistent on material points. The absence of ill motive on the part of the witnesses, and the fact that witness Nove was even related to the appellants, lent credence to their accounts.
3. The claim of self-defense by Briones failed. He did not prove the requisites of self-defense by clear and convincing evidence. There was no unlawful aggression from the victim, as witnesses saw no weapon in his possession. Even assuming the victim struck with a coconut frond, the means employed by appellants (hacking/stabbing with bolos) were not reasonably necessary. The victim’s presence with his young son made it unlikely he would provoke a fight against four individuals. Briones’s failure to immediately report the alleged attack and the defense’s failure to present Paz Camposano, who could have corroborated their story about delivering fish, further weakened the claim. The appellants’ presence at the scene was deemed part of a preconceived plan, not a coincidence.
The appellants were sentenced to suffer the penalty of reclusion perpetua and ordered to jointly and severally indemnify the heirs of the deceased in the amount of P50,000.00.