GR 183094; (September, 2010) (Digest)
G.R. No. 183094; September 22, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. REYNALDO BARDE, Accused-Appellant.
FACTS
On April 15, 1999, during a dance in Rapu-Rapu, Albay, accused-appellant Reynaldo Barde rolled and detonated a hand grenade inside the crowded dance area. The explosion resulted in the instantaneous deaths of fifteen (15) individuals and caused injuries to at least seventy-six (76) other persons. Among the injured, Purisima Dado and Ligaya Dado sustained wounds that required extensive medical treatment but survived. Appellant and his brother, Jimmy Barde, were charged with the complex crime of multiple murder with multiple frustrated murder. The prosecution presented eyewitnesses, including Elmer Oloroso, who testified to seeing appellant and his brother outside the venue before the explosion and identified appellant as the one who threw the grenade.
The Regional Trial Court convicted appellant of the complex crime and sentenced him to reclusion perpetua. On appeal, the Court of Appeals affirmed the conviction but modified the penalty, initially increasing it to death before reducing it to reclusion perpetua in line with Republic Act No. 9346. The appellate court also increased the awards for damages. Appellant’s brother, Jimmy, was acquitted due to insufficient evidence of conspiracy.
ISSUE
Whether the Court of Appeals correctly affirmed appellant’s conviction for the complex crime of multiple murder with multiple frustrated murder.
RULING
Yes, the Supreme Court affirmed the conviction. The Court upheld the factual findings of the lower courts, emphasizing that the assessment of witness credibility is best undertaken by the trial court. The positive identification of appellant by eyewitness Elmer Oloroso, who had no ill motive to falsely testify, was deemed credible and sufficient to establish guilt beyond reasonable doubt. The Court found the qualifying circumstance of treachery to be present, as the sudden detonation of a grenade in a crowded, enclosed space ensured the execution of the crime without risk to the appellant from any defense the victims might offer.
Regarding the complex crime, the Court applied Article 48 of the Revised Penal Code. The single act of detonating the grenade produced multiple grave felonies—the deaths of fifteen persons and the frustrated murder of at least two survivors (Purisima and Ligaya Dado) whose injuries were proven to be fatal without timely medical intervention. The penalty for the most serious crime (murder) was imposed in its maximum period, which is reclusion perpetua, there being no aggravating or mitigating circumstances. The awards for civil indemnity, moral damages, exemplary damages, and temperate damages were affirmed as modified by the Court of Appeals, being in accordance with prevailing jurisprudence.