G.R. No. 218200 , August 15, 2018
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. JEFFREY COLLAMAT a.k.a. “Ric-Ric”, JIMBO SALADAGA and RONILO RONDINA, Accused; JEFFREY COLLAMAT a.k.a. “Ric-Ric”, Accused-Appellant

FACTS

On January 13, 2002, at around 4:00 p.m., an altercation occurred at Analyn’s Store in Liloan, Cebu, when Benido Jumao-as, who was drinking with the victim Esmeraldo Gelido, accidentally spilled beer on the table of appellant Jeffrey Collamat and his group. The ensuing fistfight was pacified by Ramon Judaya, who offered a bottle of beer to appellant’s group as a gesture of goodwill. Later, at around 6:30 p.m., as Benido and the victim were walking away, Benido witnessed the victim being attacked. He positively identified appellant as one of the assailants who held the victim on the right side, while co-accused Ronilo Rondina held the left, and Jimbo Saladaga stabbed the victim with an ice pick. The autopsy confirmed the victim died from multiple punctured wounds.
The defense presented a denial and alibi. Appellant testified that after the initial altercation was settled, both groups continued drinking and singing until around 7:00 p.m., after which he left for his cousin’s house in Mandaue City. He claimed he was arrested the next morning as a suspect, denying any participation in the killing. The Regional Trial Court found appellant guilty of murder, a ruling affirmed by the Court of Appeals with modifications to the damages awarded.

ISSUE

Whether the Court of Appeals erred in affirming appellant Jeffrey Collamat’s conviction for the crime of Murder.

RULING

The Supreme Court affirmed the conviction. The Court upheld the factual findings of the lower courts, emphasizing that the credibility of the lone eyewitness, Benido Jumao-as, was not impaired. The witness had a clear and unobstructed view of the incident under sufficient lighting conditions along the national highway. His positive identification of appellant, whom he had interacted with for hours during the drinking session prior to the attack, was deemed credible and reliable. The defense of denial and alibi could not prevail over this positive identification, especially as appellant failed to prove it was physically impossible for him to be at the crime scene.
On the qualifying circumstance of treachery, the Court agreed with the lower courts’ assessment. The attack was sudden and unexpected. The victim was held firmly by appellant and another assailant, rendering him defenseless and unable to retaliate or escape, thereby ensuring the execution of the crime without risk to the attackers. This method directly and specifically employed by the assailants constituted treachery, qualifying the killing as murder. The Court modified the damages awarded in line with prevailing jurisprudence, increasing civil indemnity, moral damages, and exemplary damages to Seventy-Five Thousand Pesos (₱75,000.00) each, temperate damages to Fifty Thousand Pesos (₱50,000.00), with all amounts subject to six percent (6%) interest per annum from finality until full payment.