GR 123148; (April, 1999) (Digest)
G.R. No. 123148 April 20, 1999
People of the Philippines, plaintiff-appellee, vs. Marcelino Nava y dela Cruz @ Marcing, Gerald Quiliza y Orcilla @ Jay and Angelito Quiliza, accused-appellants.
FACTS
The prosecution’s case established that on November 9, 1992, in Dagupan City, Emilio Ico was fatally assaulted. Eyewitness Rodrigo Ico, the victim’s nephew, testified that upon hearing a commotion, he saw appellant Marcelino Nava on top of the prostrate victim while co-accused Gerald and Angelito Quiliza were clubbing the victim with a piece of wood. Another eyewitness, Josefina Francisco, stated she saw Angelito Quiliza initially strike the victim with wood, causing him to fall, after which Nava hacked him with a bolo while Gerald stood by brandishing another piece of wood. The victim died from massive intracranial hemorrhage due to trauma. The defense presented alibis and a different narrative, claiming the victim was the initial aggressor.
ISSUE
The core issue is whether the prosecution proved the guilt of appellants Marcelino Nava and Gerald Quiliza beyond reasonable doubt for the crime of Murder.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, giving weight to the positive identification by two eyewitnesses. Appellants’ argument that the nature of the victim’s wounds (caused by blunt instruments per the autopsy) contradicted the use of a bolo was rejected. The Court reasoned that the medico-legal testimony did not preclude a bolo’s use, as the weapon could have been dull or used in a hacking manner that caused blunt force trauma. Minor inconsistencies between the witnesses’ accounts were deemed inconsequential, as they witnessed different phases of the incident; such variances do not undermine credibility but instead indicate a lack of rehearsal. The consistent narration of the principal occurrence and the positive identification of the assailants, absent any evidence of improper motive, sufficed to establish guilt beyond reasonable doubt. The penalty imposed by the trial court was sustained.