G.R. No. 201092 ; January 15, 2014
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JOEL AQUINO y CENDANA @ “AKONG,” Accused-Appellant.

FACTS

Accused-appellant Joel Aquino was charged with Murder and violation of the Anti-Carnapping Act. The prosecution alleged that on September 5, 2002, the victim, Jesus Lita, and his ten-year-old son, Jefferson, were driving their tricycle when they were boarded by Aquino and several companions. The group proceeded to a nipa hut for a shabu session. Afterward, a demand for payment was made from Lita. When he could not pay, the group, with Lita and his son still in the tricycle, attacked him. Jefferson witnessed Aquino point a knife at him while a co-accused stabbed his father. The victim was later stabbed again elsewhere, and his body was dumped in a grassy area. The tricycle was taken. Jefferson later reported the incident to his mother and the police, positively identifying Aquino.
The defense presented a different version, claiming Aquino was elsewhere during the incident. The Regional Trial Court convicted Aquino of both charges, a decision affirmed with modifications by the Court of Appeals. Aquino appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt and questioning the credibility of the child witness, Jefferson.

ISSUE

The core issue is whether the prosecution successfully proved the guilt of the accused-appellant for the crimes of Murder and Carnapping beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court found the testimony of the child witness, Jefferson Lita, to be credible and sufficient to establish Aquino’s guilt. The Court emphasized that the assessment of witness credibility by the trial court is accorded great weight, as it had the direct opportunity to observe the witness’s demeanor. Jefferson’s account was clear, consistent, and given in a straightforward manner, detailing his traumatic experience. His young age did not detract from his credibility; in fact, his detailed narration of events, including the shabu session, the demands for money, the stabbing, and the disposal of the body, carried the ring of truth.
The Court rejected the defense of denial and alibi, which are inherently weak and cannot prevail over the positive identification by a credible witness. For the Murder charge, the qualifying circumstance of treachery was correctly appreciated, as the attack was sudden and unexpected, rendering the victim defenseless. For Carnapping, the taking of the tricycle by means of violence and intimidation, resulting in the owner’s death, was sufficiently proven. The Court modified the awarded damages, reducing moral damages to P50,000.00 and imposing interest on all damages at 6% per annum from the finality of judgment.