G.R. No. 126022 March 12, 2002
The People of the Philippines, plaintiff-appellee, vs. Raul Cantuba, Ronnie Balatucan (At Large), Romeo Balatucan, Elenito Balatucan (At Large), accused. Raul Cantuba and Romeo Balatucan, accused-appellants.

FACTS

Accused Raul Cantuba, Romeo Balatucan, Ronnie Balatucan, and Elenito Balatucan were charged with Murder for the killing of Felino Hate on January 11, 1994, in Barangay Polot, Mobo, Masbate. Only Raul Cantuba and Romeo Balatucan were arraigned and tried; the other two accused remained at large. The prosecution’s eyewitness, Rosalinda Hate (the victim’s widow), testified that she and her husband went to a store where the four accused were drinking. After her husband joined them and later tried to leave, Raul Cantuba held his hands, Ronnie Balatucan stabbed him in the chest, Elenito Balatucan stabbed him in the back, and Romeo Balatucan hacked his neck. The post-mortem examination confirmed a fatal hack wound on the neck and a stab wound near the heart. The defense, interposing denial, presented witnesses who gave a different account, claiming Ronnie Balatucan was the sole assailant after a sudden altercation and that Raul Cantuba was wounded while trying to pacify. The Regional Trial Court convicted Raul Cantuba and Romeo Balatucan of Murder and sentenced them to reclusion perpetua. Raul Cantuba’s appeal was dismissed due to his escape from detention. Romeo Balatucan appealed, challenging the credibility of the prosecution witness and the trial court’s disregard of defense witnesses.

ISSUE

Whether the trial court erred in giving credence to the testimony of the victim’s wife, Rosalinda Hate, and in convicting accused-appellant Romeo Balatucan of Murder based on conspiracy.

RULING

The Supreme Court affirmed the conviction. The testimony of Rosalinda Hate was found credible and sufficient to establish conspiracy among the accused. Mere relationship to the victim does not impair a witness’s credibility. Her clear narration of events, given from a distance of one meter, was consistent and detailed. The defense of denial could not prevail over her positive identification. The acts of the accused—Raul holding the victim, Ronnie and Elenito stabbing, and Romeo hacking—demonstrated a community of criminal purpose, establishing conspiracy. Thus, all conspirators were equally liable for the crime of Murder. The qualifying circumstance of treachery was present as the attack was sudden and rendered the victim defenseless. The penalty of reclusion perpetua and the award of civil indemnity were upheld.