GR 121998; (March, 2000) (Digest)
G.R. No. 121998 ; March 9, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TEODORICO CLEOPAS and FLORENCIO PIRAME, accused, FLORENCIO PIRAME, accused-appellant.
FACTS
On March 18, 1993, in Ubay, Bohol, Pedro Torrenueva was killed. Eyewitness Cipriano Supero testified that he saw the victim being held by accused-appellant Florencio Pirame while co-accused Epifanio Cleopas struck him with an iron pipe and Teodorico Cleopas hit him with a piece of wood on the forehead, causing his death. The body was subsequently buried in a well near the house of the Cleopas family to conceal the crime. An Information for Murder was filed against Teodorico Cleopas, Epifanio Cleopas (at large), and Florencio Pirame, alleging conspiracy, treachery, evident premeditation, and abuse of superior strength.
The Regional Trial Court convicted Teodorico Cleopas and Florencio Pirame of murder, sentencing each to reclusion perpetua and ordering them to pay indemnity and damages. Only Pirame appealed, arguing that the trial court erred in relying on the weak and improbable testimony of prosecution witnesses, particularly Supero, and in not considering alleged exculpatory statements from Demetrio Cleopas, the father of the Cleopas accused, which did not implicate him.
ISSUE
Whether the prosecution proved the guilt of accused-appellant Florencio Pirame for the crime of murder beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the testimony of eyewitness Cipriano Supero credible and consistent. Supero positively identified Pirame as the one holding the victim, facilitating the fatal attack by his co-accused. This act established Pirame’s direct participation and conspiracy in the killing. The Court rejected the defense’s claim that Supero’s testimony was unreliable, noting that minor inconsistencies on collateral matters do not undermine credibility but may even enhance it by negating rehearsal. The alleged sworn statement of Demetrio Cleopas, which did not mention Pirame, was correctly disregarded by the trial court as it was not formally offered in evidence. The defense of alibi presented by Pirame was weak and could not prevail over his positive identification. The qualifying circumstance of treachery was duly proven, as the attack was sudden and rendered the victim defenseless. The penalty of reclusion perpetua was affirmed. The award of civil indemnity and actual damages was sustained, but the award for moral and exemplary damages was deleted for lack of sufficient factual and legal basis.