GR 151834; (June, 2004) (Digest)
G.R. No. 151834 ; June 8, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. JUAN G. ESCOTE, appellant.
FACTS
Appellant Juan G. Escote was charged with Murder for the death of Carlos Dueñas on June 16, 1999, in Meycauayan, Bulacan. The prosecution presented eyewitnesses who placed him at the scene. Liza de la Cruz testified that while walking near the Pandayan Memorial Cemetery that evening, she saw a gray Lancer car and made eye contact with its driver, who glared at her. Shortly after, she heard gunshots. Another witness, Ricardo Caitum, stated he saw a man alight from a similar gray Lancer, flag down an orange Honda Civic, and shoot its driver when he refused to get out. Both witnesses positively identified Escote in open court as that driver and gunman.
The defense presented Escote as its lone witness. He interposed alibi, claiming he was in Camiguin Island working as a fisherman from September 1998 to August 1999, having escaped from the Bulacan Provincial Jail. He denied involvement and alleged he was framed. The Regional Trial Court convicted Escote of Murder qualified by treachery, sentenced him to reclusion perpetua, and ordered him to pay indemnities. His co-accused were acquitted due to lack of evidence.
ISSUE
Whether the guilt of appellant Juan G. Escote for the crime of Murder was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the credibility of the prosecution witnesses. It emphasized the doctrine that factual findings of the trial court, which had the direct opportunity to observe witness demeanor, are accorded great weight and respect on appeal. The positive identification by two eyewitnesses, who had no ill motive to testify falsely, prevailed over Escote’s defenses of alibi and frame-up.
The Court found alibi inherently weak and unsubstantiated, as Escote failed to prove it was physically impossible for him to be at the crime scene. His claim of being in Camiguin was uncorroborated. The Court also rejected the argument that poor lighting precluded identification, noting the area was illuminated by nearby residential lights, allowing the witnesses a clear view. The qualifying circumstance of treachery was correctly appreciated, as the attack was sudden and deliberate, denying the victim any chance to defend himself. The penalty of reclusion perpetua was affirmed. The Court modified the damages, awarding ₱50,000 as civil indemnity and ₱25,000 as exemplary damages due to the presence of treachery.