GR 123485; (August, 1998) (Digest)
G.R. No. 123485 August 31, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROLUSAPE SABALONES alias “Roling,” ARTEMIO TIMOTEO BERONGA, TEODULO ALEGARBES and EUFEMIO CABANERO, accused, ROLUSAPE SABALONES alias “Roling” and ARTEMIO TIMOTEO BERONGA, accused-appellants.
FACTS
On June 1, 1985, in Talisay, Cebu, a shooting incident resulted in the killing of Glenn Tiempo and Alfredo Nardo, and the wounding of Rey Bolo, Rogelio Presores, and Nelson Tiempo. The victims were riding in two vehicles allegedly ambushed by the accused. Five amended Informations were filed charging four individuals, later identified as Rolusape Sabalones, Artemio Timoteo Beronga, Teodulo Alegarbes, and Eufemio Cabanero, with two counts of murder and three counts of frustrated murder. Teodulo Alegarbes and Artemio Timoteo Beronga were the first arraigned; Alegarbes died during trial, and Cabanero remained at large. Sabalones was arrested, jumped bail, was recaptured in 1988, and then arraigned. The cases against Sabalones and Beronga were jointly tried. The Regional Trial Court (RTC) found them guilty beyond reasonable doubt of the crimes charged. They appealed to the Court of Appeals (CA), which affirmed their conviction but modified the penalties, sentencing them to reclusion perpetua for each murder. The CA then certified the case to the Supreme Court in accordance with the Rules of Court.
ISSUE
The primary issues revolve around the credibility of witness identification, the validity of defenses like alibi, and the relevance of alleged constitutional rights violations during custodial investigation, all in the context of affirming the factual findings of the lower courts.
RULING
The Supreme Court affirmed the convictions. It held that the factual findings of the trial court, as affirmed by the Court of Appeals, are generally binding and conclusive. The positive identification of the appellants by credible witnesses prevailed over their defenses of alibi. Furthermore, the Court ruled that alleged violations of constitutional rights during custodial investigation are irrelevant to the conviction because the trial court’s decision was not based on evidence obtained during such investigation but on the credible testimonies of eyewitnesses. The penalties imposed by the Court of Appeals were sustained.