GR 90301; (December, 1998) (Digest)
G.R. No. 90301 December 10, 1998
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JUANCHO GATCHALIAN, accused-appellant.
FACTS
The prosecution’s case, anchored on the testimonies of eyewitnesses Luisito Reyes and his father Agapito Reyes, established that on January 23, 1986, in Tondo, Manila, accused-appellant Juancho Gatchalian and his companion, Boyong Hagibis, attacked and killed Arthur Aumentado. The witnesses testified that they saw the accused-appellant and Hagibis, who appeared drunk, pass by a store. Later, they returned armed with a jungle bolo and an iron pipe. Upon seeing Aumentado, Hagibis exclaimed, “Pare, may kaaway tayo,” then struck the victim on the head with the pipe. As Aumentado fell, Gatchalian stabbed him twice with the bolo. The area was well-lit, and the witnesses had a clear view from short distances. The victim was pronounced dead at the hospital. The police investigation, initiated from a report by the hospital security guard, led to the statements of the eyewitnesses.
The defense presented a contrary version. Accused-appellant denied the killing and knowing Hagibis. He claimed he was attacked by the Aumentado brothers and Luisito Reyes after an accidental encounter. His aunt, Myrna Conje, corroborated his story, testifying that Arthur Aumentado struck Gatchalian on the head with a bolo, after which other individuals joined the assault. The defense asserted that Gatchalian was the victim of an aggression and that the prosecution witnesses were biased due to their relationship with the victim.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellant for the crime of murder beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction for murder, modifying only the civil indemnity. The Court found the prosecution’s evidence credible and sufficient. The positive identification by two eyewitnesses, who were consistent in their narration and had no ill motive to falsely testify, prevailed over the accused-appellant’s denial and alibi. The Court emphasized that the trial court’s assessment of witness credibility is accorded great respect. The defense of frame-up was rejected for being unsubstantiated. The Court upheld the finding of treachery (alevosia), as the attack was sudden and unexpected, depriving the victim of any chance to defend himself. The victim was first rendered defenseless by a blow to the head before being stabbed. This manner of execution directly and specially ensured the accomplishment of the crime without risk to the assailants. The qualifying circumstance of evident premeditation was correctly disregarded for lack of proof of the time when the accused determined to commit the crime. The penalty of reclusion perpetua was affirmed. The civil indemnity was increased to P50,000.00 in line with prevailing jurisprudence.