G.R. No. 108772 January 14, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROLLY OBELLO y PROQUITO, accused-appellant.

FACTS

Accused-appellant Rolly Obello y Proquito was charged with Murder for the killing of Danilo de Claro y Infante on September 1, 1991, in Quezon City. The Information alleged that appellant, conspiring with a certain “John Doe” (later identified as Antonio Go), attacked and stabbed the victim with treachery and evident premeditation. Only appellant was arraigned and tried, as Antonio Go remained at large. The Regional Trial Court found appellant guilty beyond reasonable doubt of Murder and sentenced him to Reclusion Perpetua.
The prosecution’s version, based on eyewitness Ricardo dela Cruz, stated that around 4:00 p.m. on September 1, 1991, while dela Cruz was playing mahjong in a store, he heard shouts outside. He rushed out and saw appellant holding the victim by both arms, while Antonio Go, coming from behind appellant, stabbed the victim in the abdomen with a fan knife. Appellant and Go then fled. The victim sustained three stab wounds and died. Dela Cruz chased the assailants, but appellant stopped him, saying, “Buda, hinde katalo yan.” The victim was brought to the hospital but was pronounced dead.
The defense version, as narrated by the trial court, was one of denial. Appellant testified that he was watching a mahjong game when he heard Antonio Go and the victim arguing. He went out, carrying his six-month-old daughter, and saw both men holding knives. He tried to pacify them but failed. He returned to ask for help, and when he came back, the victim was already lying face down. He claimed dela Cruz testified against him because dela Cruz had been mauled by the victim’s brothers in appellant’s presence.

ISSUE

The main issue is the credibility of witnesses, specifically whether the trial court erred in giving credence to the testimony of prosecution witness Ricardo dela Cruz and in disregarding the testimony of the accused, thereby finding appellant guilty beyond reasonable doubt of Murder.

RULING

The Supreme Court affirmed the trial court’s decision, finding the appeal without merit. The Court upheld the trial court’s assessment of witness credibility, emphasizing that the evaluation of testimony is best left to the trial judge who directly observes the witness’s demeanor. The Court found no reason to deviate from this rule, as the defense failed to show that the trial court overlooked substantial facts.
The Court found the testimony of eyewitness Ricardo dela Cruz clear, credible, and consistent. He positively identified appellant as the one who held the victim’s arms, enabling Antonio Go to stab the victim. This account was corroborated by medical findings showing the victim sustained frontal wounds, consistent with being restrained. The Court rejected appellant’s claim that he was carrying his child and trying to pacify the combatants, deeming it contrary to human instinct and unsupported by evidence.
The Court ruled that conspiracy was established. By holding the victim, appellant rendered him defenseless, directly contributing to the fatal attack. This concerted action demonstrated a common purpose to kill. The qualifying circumstance of treachery was present, as the attack was sudden and ensured the victim had no opportunity to defend himself. The Court modified the award of damages, increasing the indemnity for death to P50,000.00 and awarding P6,000.00 for funeral expenses, but deleted the award for actual damages due to lack of substantiation. The penalty of Reclusion Perpetua was affirmed.