G.R. No. 74515 June 14, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BERTITO TRIGO, accused-appellant.

FACTS

The accused-appellant, Bertito Trigo, was charged with the parricide of his wife, Alicia Dequiña Trigo. The prosecution’s case rested primarily on the eyewitness account of Marcos Fuentes. Fuentes testified that on the morning of May 30, 1983, at the Pontevedra public market, he saw Bertito Trigo stab his wife Alicia, causing her to fall. He stated he was about fifty meters away and saw blood spurting from Alicia’s chest. The medical examination confirmed Alicia died from multiple stab wounds, including one that penetrated her heart.
The defense presented a different narrative. Bertito Trigo claimed that an individual named Orline Buaco was the actual assailant. He testified that Buaco attempted to stab him, but he evaded the blow, which instead struck his wife. He asserted that Buaco then proceeded to stab Alicia multiple times. Trigo claimed Buaco had a prior grudge against him over an unpaid debt. The trial court convicted Trigo of parricide, sentencing him to reclusion perpetua and ordering indemnity.

ISSUE

The core issue is whether the trial court erred in convicting the accused based on the credibility of the prosecution witness and in finding guilt beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction, upholding the trial court’s assessment of witness credibility. The Court reiterated the established doctrine that factual findings of the trial court, which had the direct opportunity to observe witness demeanor, are accorded great weight and respect on appeal. The testimony of prosecution witness Marcos Fuentes was found to be clear, positive, and credible, with no evidence of any improper motive to falsely testify against the appellant.
The Court thoroughly rejected the defense’s alternative theory. It found the claim that Orline Buaco was the killer to be highly improbable. The logical inconsistencies were highlighted: if Buaco’s initial attack was aimed at Trigo, it was improbable for it to hit Alicia instead; if Trigo was the target, subsequent stab thrusts would logically have been directed at him, not at Alicia; and Trigo’s conduct after the incident—failing to shield his wife, leaving her alone after seeking police protection, and not returning to check on her medical condition—was inconsistent with innocence. These circumstantial facts bolstered the conclusion that Trigo was the perpetrator. The Court also corrected the trial court, ruling that Trigo’s act of going to the police station to report the incident and seek protection did not constitute voluntary surrender. Finally, the civil indemnity was increased to P30,000.00. The penalty of reclusion perpetua was affirmed.