GR 138615; (September, 2002) (Digest)
G.R. No. 138615, September 18, 2002
People of the Philippines, plaintiff-appellee, vs. Virgilio Belaong and Roy Belaong, accused; Virgilio Belaong, accused-appellant.
FACTS
An Information was filed charging Virgilio Belaong and his son Roy Belaong with the murder of Catalina Tapales on June 1, 1993, in San Dionisio, Iloilo. The prosecution presented witnesses Razel Balayon, Eduardo Arcede, and Rene Baradas. Balayon testified that around noon, she saw Roy Belaong resting by the roadside and later saw the victim walking. Eduardo Arcede testified that around 1:00 p.m., he saw Virgilio Belaong banging a woman’s head against a rock, with Roy present; Virgilio then pointed a shotgun at him, causing him to flee. Rene Baradas testified that around 3:00 p.m., he saw Roy Belaong with blood on his jacket and hands, and later saw Virgilio Belaong holding a revolver. The medico-legal report indicated the victim died from skull fractures. The defense presented an alibi; Roy claimed a certain Bagatsing Esteban committed the crime, while Virgilio claimed he was in Barotac Nuevo at the time. The trial court convicted both accused of murder. Roy later withdrew his appeal. Virgilio appealed, arguing the prosecution failed to prove motive and that the eyewitness testimonies were unreliable.
ISSUE
1. Whether the prosecution failed to prove motive for the crime.
2. Whether the testimonies of eyewitnesses Eduardo Arcede and Rene Baradas are reliable and trustworthy.
RULING
The Supreme Court affirmed the conviction with modifications. On the first issue, the Court ruled that motive is not essential for conviction when there is direct and positive identification of the accused. On the second issue, the Court found the testimonies of the prosecution witnesses credible, straightforward, and consistent. The Court upheld the trial court’s assessment of witness credibility, noting that Eduardo Arcede positively identified the appellants as neighbors and provided a clear account of the incident in broad daylight. The Court affirmed the penalty of reclusion perpetua for Virgilio Belaong and the award of P50,000 as civil indemnity. The Court modified the damages: the award for loss of earning capacity was computed at P595,584; the award of moral damages was disallowed; and the award of actual damages was reduced to P15,900.