G.R. No. 94530 . March 6, 1992.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANTE DONATO and BEN CATUIRAN, accused-appellants.

FACTS

The accused-appellants, Dante Donato and Ben Catuiran, were charged with Murder for the killing of Perjulio Batarina on March 24, 1980, in Amulung, Cagayan. The prosecution evidence, primarily through witness Dominador Pascual, established that the victim was forcibly taken to a meeting presided by Andres Balbuena. During the meeting, a land dispute was raised, after which Batarina was mauled by a group including the appellants. After he broke free and ran, he was chased, his hands were tied, and he was hacked and stabbed. He was then brought to another location where Ben Catuiran stabbed him while he was standing, and Dante Donato hacked him. Balbuena then ordered Batarina’s burial. The body was discovered nine days later.
The defense of Donato was denial, claiming the victim was killed by nine armed men. Catuiran interposed alibi, asserting he left the meeting early and went home to sleep. The trial court convicted both of murder qualified by treachery and sentenced them to reclusion perpetua.

ISSUE

The main issues were: (1) the credibility of the lone eyewitness; (2) the sufficiency of evidence to prove guilt beyond reasonable doubt; (3) the existence of conspiracy; and (4) the validity of the defenses of denial and alibi.

RULING

The Supreme Court affirmed the conviction. The testimony of a single witness, if credible and positive, is sufficient to sustain a conviction. The court found the eyewitness account of Dominador Pascual credible and consistent, and it was corroborated by the autopsy findings showing multiple stab and hack wounds, which contradicted Donato’s claim that the victim was hit only with gun butts. The defenses of denial and alibi were properly rejected. For alibi to prosper, the accused must prove physical impossibility of being at the crime scene; Catuiran failed to do so, as his residence was merely 1.5 kilometers away.
Conspiracy was correctly inferred from the appellants’ collective and coordinated actions in mauling, chasing, tying, and ultimately stabbing and hacking the victim, demonstrating a common purpose to kill. Treachery was present because the victim’s hands were tied, rendering him defenseless and ensuring the assailants faced no risk. However, evident premeditation was not proven. The Court modified the civil liability, increasing the indemnity to the heirs to P50,000.00 in line with prevailing jurisprudence.