GR 131732; (November, 1999) (Digest)
G.R. No. 131732 November 19, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. WILSON CATAMPONGAN, PAQUITO CAMAY and CASIUS CATAMPONGAN, accused, WILSON CATAMPONGAN and PAQUITO CAMAY, appellants.
FACTS
The prosecution’s evidence established that on December 9, 1988, in Barangay Matagangtang, Placer, Masbate, Antonio Villanueva, Sr. and his son were passing by when appellant Paquito Camay suddenly boxed the victim. Appellant Wilson Catampongan then held Villanueva’s arms crosswise at his back, enabling Casius Catampongan (at large) to stab him thrice with a knife. Camay further attacked the victim with a piece of wood. The incident was witnessed by the victim’s son, Antonio Villanueva, Jr., and Nila Francisco Casas. The postmortem examination revealed fatal stab wounds and multiple abrasions consistent with being hit by a blunt instrument, with the cause of death being shock due to hemorrhage.
The defense presented a contrary version, claiming that the victim, who was drunk, initiated the aggression by boxing Camay and chasing him with a bolo, stabbing him in the back. Wilson Catampongan claimed he only tried to pacify the victim. They asserted that Casius Catampongan arrived and stabbed the victim to stop him from further attacking the already-stabbed Camay. The defense argued that Camay was unconscious from his wound and unaware of subsequent events.
ISSUE
The core issue is whether the trial court erred in convicting appellants of Murder based on its assessment of witness credibility and in rejecting their defenses.
RULING
The Supreme Court affirmed the conviction. The Court reiterated the fundamental rule that the trial court’s assessment of witness credibility is accorded the highest respect, as it is in the best position to observe demeanor and conduct. The Court found no reason to deviate from this principle, as the testimonies of prosecution witnesses Antonio Villanueva, Jr. and Nila Francisco Casas were clear, consistent, and credible. Their positive identification of appellants as perpetrators prevailed over the appellants’ denial and self-serving claims.
The Court found the defense version implausible. The claim of Camay’s unconsciousness was belied by medical evidence showing his back wound was only slight. The claim that Wilson Catampongan merely acted as a peacemaker was contradicted by the positive testimony that he actively restrained the victim to facilitate the stabbing. The established facts demonstrated conspiracy, as the appellants’ concerted actions showed a common purpose to kill. The qualifying circumstance of treachery was correctly appreciated, as the attack was sudden and deliberate, rendering the victim defenseless. The Court thus upheld the penalty of reclusion perpetua and the awarded damages, modifying only the indemnity to conform with prevailing jurisprudence.