GR 142505; (December, 2003) (Digest)
G.R. No. 142505; December 11, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. EDUARDO FELIPE (at large), MA. LOURDES FELIPE and DIONISIO FELIPE, accused, MA. LOURDES FELIPE and DIONISIO FELIPE, appellants.
FACTS
On the evening of November 20, 1994, Eduardo Bagtas and his relatives were walking home in San Miguel, Bulacan. Appellants Ma. Lourdes Felipe and Dionisio Felipe, along with their co-accused Eduardo Felipe, emerged from tall grasses. Eduardo Felipe hacked the victim with a scythe, causing him to fall. Appellants were present and actively participated; Dionisio struck the victim with a piece of wood, while Ma. Lourdes urged, “Sige patayin mo,” and blocked the road to threaten the victim’s companions. Prosecution witnesses Willy, Gerardo, and Randy Bagtas positively identified the appellants, whom they knew as neighbors, under the bright moonlight. Another witness, Hipolito Bagtas, later saw the appellants continuing the attack.
The defense presented alibi, claiming appellants were elsewhere. Ma. Lourdes asserted she was sleeping and was later awakened by barangay officials, while Dionisio claimed he was in a different location. The trial court found the prosecution’s evidence credible, noting the positive identification by multiple eyewitnesses and the physical evidence, including a blood-stained shirt borrowed by Ma. Lourdes after the incident. The court convicted appellants of Murder qualified by treachery and sentenced them to reclusion perpetua.
ISSUE
Whether the trial court erred in convicting appellants of murder based on the evidence presented.
RULING
The Supreme Court affirmed the conviction. The Court emphasized the well-entrenched rule that factual findings of the trial court, especially on witness credibility, are accorded great respect and finality unless substantial facts were overlooked. The trial court correctly found the testimonies of the prosecution witnesses credible, consistent, and sufficient to establish guilt beyond reasonable doubt. Their positive identification of the appellants, whom they knew personally, under adequate moonlight, prevailed over the weak defenses of alibi and denial.
The Court upheld the finding of treachery (alevosia). The attack was sudden and unexpected, executed in a manner that deprived the victim of any chance to defend himself. The appellants, together with their co-accused, employed means to ensure the execution of the crime without risk to themselves. The qualifying circumstance of abuse of superior strength was absorbed by treachery. The Court modified the damages awarded, increasing civil indemnity and granting moral and exemplary damages in line with prevailing jurisprudence, but sustained the penalty of reclusion perpetua.