GR 225794; (December, 2017) (Digest)
G.R. No. 225794 , December 6, 2017
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. CRESENCIO CAMPIT y CRISTO and EMILIO MACAWILI, Accused, CRESENCIO CAMPIT y CRISTO, Accused-Appellant.
FACTS
Accused-appellant Cresencio Campit and his co-accused Emilio Macawili were charged with Murder for the killing of Leon Capanzana, Jr. The prosecution evidence, through eyewitnesses Leonisa and Kristine (the victim’s daughter and granddaughter), established that on July 27, 2008, an apparently drunk Campit approached the victim at his bodega to borrow money. When the victim did not heed his request, Campit suddenly drew a knife and stabbed him repeatedly. As the victim tried to escape, Macawili, who had been waiting across the road, grabbed him and stabbed him in the chest, causing him to fall. The eyewitnesses, who were about three arms’ length away, saw the entire incident but could not intervene for fear of their safety. The victim died from multiple stab wounds.
For the defense, Campit denied participation and claimed he was merely present. He testified that after a prior altercation where the victim punched him, he was on his way home when he saw Macawili suddenly appear and stab the victim. Campit claimed he pleaded with Macawili to stop and then fled, later hiding in Camarines Norte upon learning he was implicated. The Regional Trial Court convicted Campit of Murder, a decision affirmed by the Court of Appeals.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of accused-appellant Cresencio Campit for the crime of Murder.
RULING
The Supreme Court denied the appeal and affirmed the conviction. The Court upheld the factual findings of the lower courts, emphasizing that the assessment of the trial court on witness credibility is entitled to great weight. The testimonies of prosecution eyewitnesses Leonisa and Kristine were found clear, categorical, and consistent, providing a coherent narrative of the concerted attack. They positively identified Campit as the one who initiated the stabbing. This positive identification prevails over Campit’s bare denial, which is inherently weak and cannot overcome the affirmative testimony of credible witnesses.
The Court also affirmed the qualifying circumstance of taking advantage of superior strength. The attack involved two armed assailants acting in concert against a single, unarmed, and older victim, creating a situation of notorious inequality of force. This qualified the killing to Murder. The Court modified the awarded damages, increasing civil indemnity, moral damages, and exemplary damages to Php75,000 each, all with 6% interest per annum from finality until full payment. The penalty of reclusion perpetua without parole was sustained.