G.R. No. 156786 ; June 3, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. SUSANO PATEO y GARCIA alias “Sanok” and VICENTE BATUTO y JAPAY, appellants.

FACTS

Appellants Susano Pateo and Vicente Batuto were charged with Murder for the killing of Antonio Silvano. The prosecution’s version, as testified to by eyewitnesses including the victim’s daughter Ana Marie, established that on the evening of October 1, 2000, the appellants were having a noisy drinking session near Pateo’s store. Annoyed by the noise, Silvano went to the store to buy candies. Upon seeing Silvano approach, Pateo handed a bolo to Batuto, who then hid behind shrubs. After Silvano made his purchase, Batuto suddenly emerged and hacked him from behind. A struggle ensued where Silvano managed to stab Batuto with a knife he was carrying. Pateo then intervened, striking Silvano with a blunt instrument, which caused Silvano to drop his knife and flee. Batuto pursued and repeatedly hacked the fallen Silvano, delivering a final thrust that caused his death.
The appellants presented a different narrative. Batuto claimed self-defense, alleging that a drunk and armed Silvano attacked him first, forcing him to retaliate. Pateo denied participation, claiming he merely remained inside his store during the incident. The Regional Trial Court convicted both appellants of Murder, sentencing them to reclusion perpetua and ordering them to pay civil indemnity.

ISSUE

Whether the trial court erred in convicting the appellants of Murder, giving credence to the prosecution’s evidence over the defenses of self-defense and denial.

RULING

The Supreme Court affirmed the conviction. The Court found no reason to disturb the trial court’s assessment of the witnesses’ credibility, noting that inconsistencies in the testimonies of the prosecution witnesses were minor and did not affect the core narrative of the crime. The defenses of self-defense and denial were properly rejected. For self-defense, Batuto failed to prove the essential elements of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. His flight from the scene and failure to report the incident immediately contradicted his claim. Denial, being inherently weak, could not prevail over the positive and categorical identification by eyewitnesses of Pateo’s active participation in the assault.
The Court upheld the finding of conspiracy, evidenced by the appellants’ concerted actions: Pateo handing the bolo to Batuto and later joining the attack to ensure the victim’s demise. Treachery was correctly appreciated because Batuto’s act of hiding to launch a sudden and unexpected attack from behind ensured the execution of the crime without risk to himself arising from any defense the victim might make. The penalty of reclusion perpetua and the award of P50,000.00 as civil indemnity were affirmed.