GR 140277; (June, 2001) (Digest)
G.R. No. 140277 ; June 6, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GUILLERMO BALDAGO y LAGUNA alias “ONDOY”, TEMOTEO MADULEN y LAGUE and CARLITO BANGCAS y MESO, accused. TEMOTEO MADULEN y LAGUE and CARLITO BANGCAS y MESO, accused-appellants.
FACTS
Accused Guillermo Baldago, Temoteo Madulen, and Carlito Bangcas were charged with Murder for the death of Florentino Casas on May 17, 1998, in Barangay Old Kibawe, Bukidnon. The information alleged they conspired, armed with a hunting knife, a piece of wood, and stones, and attacked the victim with treachery and evident premeditation. Baldago pleaded guilty and was sentenced to reclusion perpetua. Trial proceeded against Madulen and Bangcas. The prosecution’s version, based on eyewitness accounts, was that Florentino Casas was drinking on the balcony of Edilberto Ybañez’s house when Guillermo Baldago suddenly went up and stabbed him. Almost simultaneously, Temoteo Madulen struck the victim with a belt, and Carlito Bangcas hit him with a piece of wood. The victim ran inside, pursued by Baldago. After the initial attack, Madulen and Bangcas stoned the house. The accused-appellants raised alibi and denial as defenses, claiming they were elsewhere at the time of the incident. The trial court found Madulen and Bangcas guilty of murder and sentenced them to reclusion perpetua and to solidarily indemnify the victim’s heirs.
ISSUE
1. Whether the trial court erred in giving credence to the allegedly conflicting testimonies of the prosecution witnesses.
2. Whether the trial court erred in convicting the accused-appellants based on conspiracy to commit murder.
RULING
The Supreme Court affirmed the trial court’s judgment. On the first issue, the Court held that the alleged inconsistencies in the testimonies of prosecution witnesses Leonila Oroyan and Edilberto Ybañez were minor and did not affect their credibility regarding the essential fact of the accused-appellants’ participation in the crime. The Court emphasized that witnesses testifying on the same event may differ in their recollections of minor details. On the second issue, the Court ruled that conspiracy was sufficiently established. The accused-appellants, together with Baldago, came from a cockpit, waylaid the victim’s nephew, and then proceeded together to the scene where they almost simultaneously attacked the victim without warning. Their collective actions before, during, and after the incident demonstrated a community of design, making the act of one imputable to all. The Court found that the qualifying circumstance of treachery was present, as the attack was sudden and unexpected, giving the victim no opportunity to defend himself. The defenses of alibi and denial were rejected for being weak and uncorroborated.