GR 133445; (February, 2003) (Digest)
G.R. No. 133445 ; February 27, 2003
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DIONESIO SANTIAGO, accused-appellant.
FACTS
Accused-appellant Dionesio Santiago was charged with double murder for the killing of Igmedio Carigay and Myrna Samsona on December 31, 1993. The prosecution established that the accused had a prior violent altercation with Igmedio over irrigation rights. Two days before the incident, a witness heard the accused swear to kill Igmedio before the month ended. On the night of the crime, another witness, Manuel Magsipoc, met a group of five men, including the unmasked accused who was armed with a bolo, walking toward the victims’ house. The key eyewitness, Bien Beloya, later approached the house and heard Myrna pleading for their lives and the accused threatening to kill them all. Bien then saw Igmedio run from the house, pursued by the accused and four masked companions, who then surrounded and stabbed him. Bien was seen, prompting a chase, and the accused later threatened him to leave town.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellant for two counts of murder beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction with modifications. The Court found the testimony of eyewitness Bien Beloya credible, positive, and consistent. His presence at the scene was natural, as he was invited for a New Year’s Eve celebration, and his detailed account, including the accused’s direct threats and the subsequent chase, was deemed reliable. The defense of alibi was rejected for being weak and unsubstantiated. The Court ruled that the killing of Igmedio constituted murder qualified by treachery, as the attack was sudden and rendered the victim defenseless. For Myrna, who was killed inside the dwelling, the crime was also murder, with the qualifying circumstance of dwelling. However, applying the retroactive effect of the 2000 Revised Rules of Criminal Procedure, the information was defective for charging two murders in a single count. Since the accused failed to move to quash, he was deemed to have waived the objection, and the court properly convicted him for two separate counts. The penalty of reclusion perpetua for each count was upheld. The awards for damages were modified, granting civil indemnity, moral damages, and exemplary damages to the heirs of each victim.