GR 133027; (March, 2004) (Digest)
G.R. No. 133027 ; March 4, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. PAUL TAGANA, RUEL BIBOHAN, and RODOLFO LINANGA, appellants.
FACTS
On September 30, 1995, in Cagayan de Oro City, the victim Celestino Buoy was drinking with appellants Paul Tagana, Ruel Bibohan, Rodolfo Linanga, and an at-large accused, Conrado Tagana. The victim’s wife, Helen, and mother, Marcita, were present. After drinking, the group moved towards a road. Prosecution witnesses testified that Rodolfo Linanga held the drunk victim while all four assailants took turns stabbing him before dumping his body in a canal. The autopsy revealed seven stab wounds and ten incised wounds, which the medico-legal officer opined could have been inflicted by more than one person.
The defense presented a different account, claiming Paul Tagana acted alone in self-defense. They alleged the victim challenged the group, kicked Paul, and a struggle ensued during which Paul, in defense, stabbed the victim. A defense witness, Aurelio Española, claimed he saw only two persons involved in the stabbing incident. The Regional Trial Court convicted all three appellants of Murder, qualified by treachery, and sentenced them to reclusion perpetua.
ISSUE
Whether the prosecution proved beyond reasonable doubt the guilt of appellants Paul Tagana, Ruel Bibohan, and Rodolfo Linanga for the crime of Murder.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the testimonies of the prosecution eyewitnesses—the victim’s wife and mother—to be credible, natural, and consistent. Their positive identification of all appellants as participants in the concerted attack was deemed reliable, as they had no motive to falsely testify. The medical findings corroborated their account, indicating multiple assailants. The defense of self-defense by Paul Tagana was rejected for being inherently weak and uncorroborated by clear and convincing evidence; the nature, number, and location of the victim’s wounds were inconsistent with a claim of self-defense.
The Court upheld the finding of treachery. The attack was sudden and unexpected, executed in a manner that rendered the drunk and unarmed victim incapable of any defense. The appellants employed means that deliberately ensured the execution of the crime without risk to themselves. The Court also found conspiracy, as the appellants’ collective and simultaneous actions in stabbing the victim demonstrated a common purpose to kill. The penalty of reclusion perpetua was affirmed, and civil indemnity was increased to P75,000.00, with moral damages of P50,000.00 and exemplary damages of P25,000.00 awarded to the heirs.