GR 174371; (December, 2008) (Digest)
G.R. No. 174371 December 11, 2008
THE PEOPLE OF THE PHILIPPINES, petitioner, vs. WARREN DELA CRUZ Y FRANCISCO, respondent.
FACTS
On May 9, 1999, at around 2:45 p.m., Leonardo Cayetano was walking ahead of Danilo Valeriano and Felix Valeriano towards a cockpit arena in Dampalit, Malabon. Leonardo suddenly heard gunshots, turned around, and saw Danilo and Felix already sprawled and bloodied on the ground. He saw three persons, including appellant Warren dela Cruz who was firing a .38 caliber gun, continue shooting the victims. Leonardo ran for safety and later found the victims dead. An autopsy revealed the victims died of multiple gunshot wounds fired at close range. Appellant and two John Does were charged with two counts of Murder. Appellant pleaded not guilty and invoked the defense of denial, claiming he was also accosted by three masked men who held him at gunpoint during the shooting. The Regional Trial Court convicted appellant of two counts of Murder, sentenced him to reclusion perpetua for each count, and ordered him to pay civil indemnity and actual damages. The Court of Appeals affirmed the conviction with modification, adding an award of moral damages.
ISSUE
1. Whether the trial court erred in giving full weight and credence to the testimony of prosecution witness Leonardo Cayetano and in disregarding the defense of the accused-appellant.
2. Whether the accused-appellant’s guilt was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the decision of the Court of Appeals. The trial court’s assessment of witness credibility is accorded great weight and respect. The alleged inconsistencies in Cayetano’s testimony referred only to minor details, such as the exact time he gave his statement to the police, and did not impair his credibility. Such minor inconsistencies can even strengthen credibility as badges of truth. Cayetano positively identified appellant as one of the assailants, and his testimony was straightforward. Appellant’s defense of bare denial cannot prevail over this positive identification. The Court also found that appellant’s flight after the incident evinced a consciousness of guilt. The qualifying circumstance of treachery was present, as the attack was sudden, from behind, and gave the unarmed victims no opportunity to defend themselves. The Court upheld the penalty of reclusion perpetua for each count of Murder and the awards of civil indemnity, moral damages, and actual damages.