G.R. No. 75619 ; April 3, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DIONISIO DINGLASA, accused-appellant.

FACTS

Accused-appellant Dionisio Dinglasa was convicted of murder for killing Saturnino Niaga by hitting him with a rock. The incident occurred on August 21, 1977, in Barrio Tolosa, Malabuyoc, Cebu. The prosecution’s case rested primarily on the testimonies of two eyewitnesses: Amando Niaga, the victim’s son, and Porferio Dinglasa, the accused’s own uncle. They testified that after attending a cockfight, the group, including the victim, the accused, and the witnesses, was walking home in single file on a moonlit night. Dionisio Dinglasa suddenly picked up a rock and hurled it at Saturnino, hitting him on the back of the head. Saturnino cried out that Dionisio had attacked him. Amando rushed to help but was also hit by stones thrown by Dionisio. The victim later made ante mortem statements to his wife and a police officer, identifying Dionisio as his assailant, before succumbing to his injuries two days later.
The defense presented an alternative version, claiming that it was Porferio Dinglasa, not Dionisio, who threw the fatal stone, and that Amando was not present. This was supported by the testimony of Abdon Mayola. The defense also sought to discredit the victim’s dying declaration by presenting medical testimony suggesting he was unconscious upon hospital admission. The trial court, however, found the defense evidence unreliable, noting inconsistencies, Mayola’s credibility issues as a “professional witness,” and the compelling, consistent accounts of the prosecution’s eyewitnesses.

ISSUE

Whether the trial court erred in convicting the accused-appellant of murder based on the evidence presented.

RULING

The Supreme Court affirmed the conviction. The trial court correctly analyzed the evidence. The positive and categorical testimonies of the two eyewitnesses, one of whom is the accused’s own uncle, were found credible and consistent, establishing the appellant’s guilt beyond reasonable doubt. Their account was corroborated by the victim’s ante mortem statements, both oral and written, which qualified as dying declarations given his expressed fear of impending death. The Court upheld the trial court’s assessment of witness credibility, finding the defense’s alternative narrative unconvincing. The defense witness was impeached, and the medical testimony did not conclusively negate the victim’s capacity to make a statement, especially in light of the police officer’s direct testimony to the contrary. The appellant’s flight and failure to report the incident further indicated guilt. No reversible error was found in the trial court’s factual findings or legal conclusions. The penalty of reclusion perpetua and the award of indemnity were sustained.