GR 76391; (April, 1989) (Digest)
G.R. Nos. L-76391-92 April 25, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DOMINGO BAYSA and ROGELIO BAYSA, accused-appellants.
FACTS
The appellants, Domingo Baysa and Rogelio Baysa, were convicted by the Regional Trial Court of Tacurong, Sultan Kudarat, for the double murder of Casimiro Ordanza and Martiniano Acosta on the evening of June 25, 1978. The prosecution’s case rested primarily on the eyewitness accounts of Eulalia Acosta Vda. de David and Fernando Bibat for the killing of Martiniano Acosta, and Antonio Yabut for the killing of Casimiro Ordanza. Eulalia and Bibat testified that they were inside the Acosta house when they saw the appellants, along with the now-deceased Elpidio Baysa, approach. They heard gunshots and Martiniano Acosta’s cry, after which they saw him dead. Antonio Yabut testified that he heard gunshots and saw Casimiro Ordanza, who was calling for help, being pursued and shot by the appellants.
ISSUE
The core issue is whether the prosecution evidence, particularly the testimonies of the eyewitnesses, is credible and sufficient to prove the guilt of the appellants beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction, upholding the trial court’s assessment of witness credibility. The Court methodically rejected the appellants’ challenges. First, it found no ill motive for the witnesses to falsely testify; their relationship to the victim was deemed natural and does not impair credibility. Second, the Court dismissed alleged inconsistencies in the witnesses’ statements made during an ocular inspection five years after the crime. It ruled that minor discrepancies in recalling details after a long period are normal and do not indicate fabrication, especially when the testimonies are consistent on material points like the positive identification of the appellants as the perpetrators. The Court emphasized that where witnesses provide coherent and corroborated narratives on the central facts of the crime, minor inconsistencies do not undermine their overall credibility. The postmortem findings corroborated the eyewitness accounts. Consequently, the guilt of the appellants was established beyond reasonable doubt. The penalty for one murder count was modified to reclusion perpetua in line with constitutional prohibitions, and indemnity was standardized to P30,000 for each victim, while awards for actual damages were affirmed.