G.R. No. 117398 August 15, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANDRES DABBAY, accused-appellant.

FACTS

The case involves the murder of Jacinto Sibal, whose hog-tied body was found floating in the Cagayan River on February 16, 1992. Andres Dabbay, along with his brother Alfonso, cousin Rolly, and neighbor Dante Tuliao, was charged with murder, alleged to have been committed with treachery and evident premeditation. The prosecution’s narrative established that three days prior to the killing, Jacinto had reported to his mother that he witnessed appellant Andres Dabbay and others stealing his grandmother’s pig. On the night of February 15, Jacinto attended a local benefit dance and was later seen joining a drinking session with the accused. A commotion erupted at the dance hall when stones were thrown, causing attendees to disperse. A key witness, Dominador Ragingan, testified that as he fled, he saw appellant Andres Dabbay tying up Jacinto, who was being held by two others, while a fifth person held a knife. Appellant threatened Ragingan not to reveal what he saw. The following morning, Jacinto’s body was discovered with multiple stab wounds and hematomas.

ISSUE

The core issue is whether the prosecution evidence, particularly the eyewitness testimony of Dominador Ragingan, is sufficient to prove the guilt of appellant Andres Dabbay for the crime of murder beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the credibility of the lone eyewitness and the principle of conspiracy. The Court held that the testimony of Dominador Ragingan was clear, credible, and consistent on material points. He positively identified appellant as the person tying the victim while others restrained him, and he directly received a death threat from appellant to ensure his silence. The Court rejected the defense’s claim of inconsistencies between Ragingan’s testimony and that of the victim’s brother, Edmundo, noting that different witnesses may have varying perceptions of the same event, especially during a chaotic incident. The minor discrepancies were deemed inconsequential to the core narrative of appellant’s direct participation. Furthermore, the Court applied the doctrine of conspiracy, wherein the act of one conspirator is the act of all. Even though Ragingan could not identify all individuals present, appellant’s active role in restraining the victim and issuing threats established his integral part in the concerted criminal design. The trial court’s assessment of witness credibility was accorded great respect, as it was in the best position to observe demeanor. No substantial reason was found to overturn its findings. Consequently, appellant’s guilt for murder, qualified by treachery as the hog-tying rendered the victim defenseless, was proven beyond reasonable doubt.