G.R. No. 139823 ; March 12, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. ROWEN SAMPAGA y LIMENOQUEN alias “WENG,” RICO TRINIDAD y RAFAEL alias “PARDS,” and LINO CORONA y DELA CRUZ alias “Jhun,” accused. RICO TRINIDAD y RAFAEL alias “PARDS,” appellant.

FACTS

On December 25, 1997, around 1:00 AM in Baliuag, Bulacan, a commotion ensued at a compound housing several beerhouses. Accused Rowen Sampaga, Lino Corona, and appellant Rico Trinidad were initially seen in a fistfight with a helper from a neighboring establishment. Lucila Castillo, a beerhouse owner, sought the assistance of the victim, Jaime Bautista, who was the PRO of the beerhouse operators’ association. Upon their return, the accused were seen damaging property. When Bautista appeared and said “Awat, awat” (Stop it), Corona struck him on the back with a lead pipe. Sampaga and Trinidad, armed with pieces of wood, joined in the attack, hitting Bautista multiple times until he fell with fatal head injuries. The area was illuminated, and Castillo witnessed the assault from a close distance. The accused fled but were apprehended later that day.
The defense presented a different version, alleging that a certain Bobbit Bermudez was the actual killer. They claimed that after a separate altercation, Bautista blocked Sampaga’s path armed with a lead pipe, and Bermudez suddenly appeared and attacked Bautista from behind. The accused claimed they fled out of fear of being implicated. Appellant Rico Trinidad also interposed an alibi, asserting he was at home during the incident.

ISSUE

Whether the prosecution proved the guilt of appellant Rico Trinidad for the crime of Murder beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed appellant’s conviction for Murder qualified by treachery, but modified the awarded damages. The Court upheld the trial court’s assessment of the credibility of prosecution eyewitness Lucila Castillo, whose positive identification of the appellant was clear, consistent, and given under good visibility. Her testimony established that the attack on the victim was sudden and from behind, leaving him no opportunity to defend himself, thereby qualifying the killing with treachery. The defense of denial and alibi cannot prevail over this positive identification. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime occurred but also that it was physically impossible for him to be at the scene. Appellant failed to establish such physical impossibility. The defense story pointing to another assailant was deemed unconvincing and fabricated. The Court sentenced appellant to reclusion perpetua and ordered him to pay the heirs of the victim P50,000 as civil indemnity, P50,000 as moral damages, P75,000 as actual damages, and P25,000 as exemplary damages. The award of P500,000 for unearned income was deleted for lack of sufficient factual basis.