G.R. No. 179476; February 9, 2011
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RUEL TUY, Accused-Appellant.

FACTS

Accused-appellant Ruel Tuy, together with Ramon Salcedo, Jr. and Raul Salcedo (who remained at large), was charged with Murder for the killing of Orlando Barrameda on October 11, 2001, in Brgy. Bani, Tinambac, Camarines Sur. The information alleged conspiracy, use of firearms and a bolo, and the attendance of treachery. The victim was the incumbent barangay captain. Upon arraignment, Tuy pleaded not guilty. During trial, the prosecution presented Severino Barrameda, the victim’s son, who testified that he witnessed the Salcedos shooting and Tuy hacking his father. Dr. Salvador Betito, Jr., the medico-legal officer, established through autopsy that the victim sustained five hack wounds and two gunshot wounds, with the cause of death being rapid hemorrhage. For the defense, Tuy denied participation, claiming he was processing copra in Sitio Olango, Brgy. Bani at the time, an alibi corroborated by his brother Ramil Tuy. The Regional Trial Court (RTC) convicted Tuy of Murder, sentencing him to reclusion perpetua and ordering him to pay civil indemnity, moral damages, and actual damages. The Court of Appeals (CA) affirmed the conviction, rejecting Tuy’s defenses. Tuy appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals committed reversible error in affirming the conviction of accused-appellant Ruel Tuy for Murder.

RULING

The Supreme Court affirmed the decision of the CA, upholding Tuy’s conviction for Murder. The Court held: (1) The factual findings of the RTC, especially when affirmed by the CA, are accorded the highest degree of respect and are final and conclusive, as there was no clear misapprehension of facts in appreciating the eyewitness testimony of Severino Barrameda. (2) The defense of alibi was properly rejected. Tuy failed to prove the physical impossibility of his presence at the crime scene, as he admitted the distance between Brgy. Olango and Brgy. Bani could be navigated in an hour by paddle boat or less by motorized banca. His alibi was further negated by the positive identification by eyewitness Severino. (3) The medico-legal evidence corroborated Severino’s account of the hacking. On civil liability, the Court modified the awards in accordance with prevailing jurisprudence for crimes covered by Republic Act No. 7659: civil indemnity was increased to ₱75,000.00; moral damages to ₱75,000.00; and exemplary damages of ₱30,000.00 were added. The penalty of reclusion perpetua was affirmed.