GR 121039; (October, 2001) (Digest)
G.R. Nos. 121039-45; October 18, 2001
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MAYOR ANTONIO L. SANCHEZ, et al., accused-appellants.
FACTS
This is a resolution on the motions for reconsideration filed by accused-appellants Mayor Antonio Sanchez, Zoilo Ama, Baldwin Brion, and Pepito Kawit, seeking to overturn the Supreme Court’s January 25, 1999 decision which affirmed their conviction for seven counts of rape with homicide. The appellants were sentenced to reclusion perpetua for each count and ordered to pay substantial damages. Sanchez argued he was a victim of a trial by publicity, challenged the credibility of the principal prosecution witnesses (Aurelio Centeno and Vicencio Malabanan), and contested the damages awarded as excessive and baseless. Similarly, appellants Ama, Brion, and Kawit asserted that these witnesses were impeached by prior inconsistent statements and that disinterested witnesses contradicted the prosecution’s narrative.
ISSUE
The core issues for reconsideration were: (1) whether the conviction was vitiated by prejudicial publicity; (2) whether the trial court erred in crediting the testimonies of prosecution witnesses Centeno and Malabanan; and (3) whether the awarded civil damages had factual and legal basis.
RULING
The Supreme Court denied the motions for reconsideration on the criminal liability but modified the civil awards. On the publicity claim, the Court reiterated that pervasive media coverage does not equate to prejudicial publicity absent proof of actual bias or influence on the trial judge. Citing People vs. Teehankee, Jr., the Court emphasized that judges are trained to disregard external influences, and the appellant failed to discharge the burden of proving the judge acquired a fixed, biased position incapable of change by trial evidence. Regarding witness credibility, the Court upheld the trial court’s findings, noting the rule that appellate courts generally defer to the trial court’s assessment of witness demeanor and truthfulness, which it found to be frank and straightforward. The prior inconsistencies were deemed insufficient to overturn this assessment.
However, the Court modified the civil liability. It recalculated the loss of earning capacity for victims Eileen Sarmenta and Allan Gomez using the formula in Villa Rey Transit, Inc. vs. CA, resulting in awards of P2,361,180.00 and P2,441,220.00, respectively. The moral damages were reduced from P2,000,000.00 to P1,000,000.00 for each set of heirs, ruling that while discretionary, such awards must be proportionate to the suffering and aimed at spiritual restoration, not enrichment or punishment. Other awards for death indemnity, funeral expenses, and attorney’s fees were affirmed. The conviction and sentences of reclusion perpetua were sustained.