G.R. No. 118080 May 7, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REYNALDO “RENATO” DATUN, RONALD “OTIC” SEÑEREZ, ELVIS ESTOLOGA, PEDRO ESMAYA, JR., and CONSTANTINO VEJO, JR., accused-appellants.

FACTS

On March 18, 1992, Anastacio Solidarios and Baltazar Nagallo were walking home in Barangay New Visayas, Sto. Tomas, Davao, when they passed a group, including appellants Datun and Señerez, having a drinking session. The group invited them to drink. After briefly going to Solidarios’s house, the two men returned to join them. Upon arrival, Solidarios made a comment about the newly installed water pump. Immediately, the group stood up and surrounded him. Constantino Vejo Jr. struck Solidarios’s leg with a stick, followed by Pedro Esmaya hitting the back of his neck, causing him to fall. While he was down, Elvis Estologa stabbed his chest, Ronald Señerez stabbed his left side, and Reynaldo Datun hacked his head with a bolo. The assailants then fled. The victim’s wife, Epifania, witnessed the attack and pleaded in vain for them to stop. Solidarios died from his injuries.
Only Datun and Señerez were apprehended and tried; the other three accused remained at large. At trial, the prosecution presented eyewitness accounts from Baltazar Nagallo and Epifania Solidarios. The defense of the appellants consisted of alibi and denial, claiming non-participation in the crime. They specifically attacked the credibility of the eyewitnesses by pointing out that the fatal head blow testified to was not listed in the victim’s death certificate issued by the municipal health officer.

ISSUE

Whether the death certificate, which did not list a head injury, can discredit the consistent and positive eyewitness testimonies regarding the manner of the attack that led to the victim’s death.

RULING

The Supreme Court affirmed the conviction. The Court held that a death certificate’s primary purpose is to establish the fact of death and its immediate, antecedent, and underlying causes as medically determined. It is not a comprehensive record of every injury sustained by the victim. The absence of a specific injury in the death certificate does not negate its occurrence, especially when clearly and consistently testified to by credible eyewitnesses. The Court found the testimonies of Nagallo and Epifania Solidarios to be clear, credible, and consistent on material points, including the collective and sudden attack by five armed men. Their relationship to the victim did not impair their credibility, as the Court has often held that a witness’s relationship to the victim can even lend credence to their testimony, as they would be most interested in seeing justice served.
Furthermore, the Court upheld the finding of treachery (alevosia). The attack was sudden and deliberate, executed by a group that surrounded the unarmed victim, giving him no opportunity to defend himself or escape. The means employed directly ensured the execution of the crime without risk to the assailants. The aggravating circumstance of abuse of superior strength was deemed absorbed in treachery. The defense of alibi was rejected for being weak and unsubstantiated, especially in light of the positive identification by the prosecution witnesses. The penalty of reclusion perpetua and the awards for civil indemnity and actual damages were affirmed.