G.R. No. 73907 May 18, 1993
People of the Philippines, plaintiff-appellee, vs. Buenaventura Aruta, Nathaniel Quinones, and John Doe, accused-appellants.

FACTS

On December 26, 1982, at about 7:00 PM in Jaro, Leyte, Cesar Galvez was stabbed to death. Three men were charged with murder: Nathaniel Quinones, Buenaventura Aruta, and an unidentified John Doe. Quinones was shot dead before arraignment, and John Doe remained at large, leaving only Aruta as the appellant. The prosecution presented two eyewitnesses, Adriano Marmita and Martin Rombo, who both testified that Aruta, Quinones, and another person attacked Galvez. Marmita testified that Quinones restrained Galvez and shouted “Fight him!”, upon which Aruta and another emerged and stabbed Galvez. Rombo gave a substantially similar account. The autopsy by Dr. Prudencio Fevidal showed death was caused by severe hemorrhage from four stab wounds. Aruta presented an alibi, claiming he was 60 kilometers away in Ormoc City at the time, drinking at his compadre’s house, which was corroborated by Mariano Dagle. Two other defense witnesses, Samuel Dejano and Wilfredo Garrido, claimed only Quinones committed the killing. Pat. Perfecto Villamor testified that initial investigations did not mention Aruta as an assailant.

ISSUE

Whether the trial court erred in convicting accused-appellant Buenaventura Aruta of murder despite alleged reasonable doubts about his guilt, including inconsistencies in prosecution witness testimonies, the plausibility of the alibi, and the defense theory that only one weapon (and thus one person) inflicted the wounds.

RULING

The Supreme Court affirmed the conviction, as modified. The trial court’s assessment of witness credibility is accorded great respect and is conclusive when supported by the evidence. The minor inconsistencies in the prosecution witnesses’ testimonies do not detract from their essential veracity. The medical examiner debunked the defense theory by stating the wounds could have been caused by different persons using identical weapons. Rombo’s delay in reporting was reasonably explained. The alibi was inherently weak and properly rejected by the trial court. A conspiracy existed among the three assailants, making the act of one the act of all; thus, Quinones’s acts are imputable to Aruta. Motive, though not essential due to positive identification, was traceable to rivalry between groups operating “masiao.” The killing was qualified by treachery as the victim was taken by surprise. Evident premeditation was not proved. The penalty of reclusion perpetua was affirmed, and the civil indemnity was increased to P50,000.00.