GR 160811; (April, 2008) (Digest)
G.R. No. 160811 , April 14, 2008
Ricky Bastian, petitioner, vs. Hon. Court of Appeals and People of the Philippines, respondents.
FACTS
On April 25, 1995, around 2:00 a.m., Lorna Bandiola was leaving a school dance in Nabas, Aklan with her children when she saw her son-in-law, John Ronquillo, walking ahead. She then witnessed petitioner Ricky Bastian step forward, draw a gun, and shoot Ronquillo in the head. Bastian continued firing at the fallen victim. Lorna heard Bastian’s companions state, “He is dead already,” before the group fled. The police recovered a bullet slug at the scene, and an autopsy confirmed multiple gunshot wounds caused Ronquillo’s death. Bastian, along with three others, was charged with murder.
The defense presented an alibi, claiming Bastian was drinking at a barangay captain’s house until past midnight and slept there, learning of the shooting only the next day. The trial court, however, found Lorna’s eyewitness account credible, noting her clear view and proximity to the event. It convicted Bastian of homicide, acquitting his co-accused for insufficient evidence, and sentenced him to an indeterminate penalty. The Court of Appeals affirmed the conviction.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of Ricky Bastian for homicide based on the credibility of the prosecution’s eyewitness.
RULING
The Supreme Court denied the petition and affirmed the conviction. The Court emphasized that the trial court’s assessment of witness credibility is accorded the highest respect, as the trial judge is in the optimal position to observe the witnesses’ demeanor and calibrate their testimonies. The defense of alibi, which Bastian interposed, is inherently weak and cannot prevail over the positive and categorical identification by an eyewitness who had no ill motive to testify falsely. Lorna Bandiola’s testimony was clear, consistent, and credible, establishing that Bastian was the perpetrator.
The Court further ruled that the claim of responsibility by the New People’s Army (NPA) for the killing, as alleged by the defense, does not bind the courts. The judiciary must determine criminal liability based on the evidence presented during trial. The prosecution successfully proved Bastian’s guilt beyond a reasonable doubt through direct evidence. The modifying circumstance of nighttime was correctly appreciated as it was deliberately sought to facilitate the crime. Consequently, the penalty and awarded damages were upheld as proper.