G.R. No. 179497; January 25, 2012
PEOPLE OF THE PHILIPPINES, Appellee, vs. RENANDANG MAMARUNCAS and PENDATUM AMPUAN, Appellants.

FACTS

On February 1, 1996, around noontime, Baudelio Batoon, Richard Batoon, Juanito Gepayo, and a certain “Nito” were working at Baudelio’s auto repair shop in Tubod, Baraas, Iligan City. Baginda Palao (alias Abdul Wahid Sultan), accompanied by appellants Renandang Mamaruncas and Pendatum Ampuan, entered the shop. Palao showed an arrest warrant to Baudelio Batoon. When Batoon asked to finish tuning an engine first, Palao slapped his stomach and pointed a .45 caliber pistol at him. A struggle for the gun ensued between Batoon and Palao. During this grapple, Mamaruncas, standing behind Batoon, shot him in the right thigh with a .38 caliber homemade gun. Ampuan, also behind Batoon, then shot him in the left armpit with a .45 caliber homemade pistol. Batoon fell, and Palao shot him in the back. Witnesses Juanito Gepayo and Richard Batoon, positioned three to four meters away, saw the entire incident. Police officers, including Inspector Graciano Mijares, who were passing by, heard the gunshots, intervened, and exchanged fire with the assailants. Mamaruncas and Ampuan were shot, captured, and later detained. Palao escaped. Baudelio Batoon was pronounced dead on arrival at the hospital. The necropsy report by Dr. Leonardo Labanen indicated three gunshot wounds inflicted at close range. Appellants pleaded not guilty and claimed innocence. Mamaruncas testified he was merely waiting in a car and was handed a gun by Palao, while Ampuan claimed he was not at the scene of the shooting.

ISSUE

Whether the trial court’s assessment of the credibility of the prosecution witnesses and its consequent finding of guilt against appellants for the crime of murder should be upheld.

RULING

Yes. The Supreme Court affirmed the conviction. The trial court’s findings on the credibility of witnesses are accorded great weight and respect, as it had the direct opportunity to observe their demeanor. No facts of substance were overlooked that would alter the case’s outcome. The positive identification by eyewitnesses Juanito Gepayo and Richard Batoon, who had a clear and unobstructed view from a short distance, was credible and consistent. Their testimonies established that appellants, conspiring with Baginda Palao, attacked and killed Baudelio Batoon. The qualifying circumstance of treachery was present because the attack was sudden and from behind, rendering the victim unable to defend himself. The crime is Murder under Article 248 of the Revised Penal Code. The Court modified the penalty to reclusion perpetua, in line with Republic Act No. 9346, and affirmed the awarded damages.