GR 94702; (October, 1995) (Digest)
G.R. No. 94702 October 2, 1995
People of the Philippines vs. Carlito Acuña, Jesus Ramos and Antonio (Tony) Dionisio
FACTS
Appellants Jesus Ramos and Antonio Dionisio, along with the at-large Carlito Acuña, were charged with the murder of Tranquilino Mariano. The prosecution evidence established that on the evening of November 22, 1988, the three accused fetched Mariano from his house. Eyewitnesses Victoria Magaña and Luisa Blanco later saw the trio quarreling with Mariano at the pasibi of Ramos’s house. From a distance of two arms’ length, they witnessed Acuña hit Mariano’s head with a piece of wood while Ramos and Dionisio held his arms. After Mariano fell, all three took turns stabbing him. The victim’s body, bearing twelve stab wounds, was discovered the next morning. The defense of appellants consisted of denial, with Ramos claiming Mariano left his house alive on a bicycle and Dionisio claiming he merely saw the corpse the next day.
ISSUE
Whether the trial court erred in convicting the appellants based on the credibility of the prosecution eyewitnesses.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, emphasizing that the trial judge is in the best position to evaluate the witnesses’ demeanor and sincerity. The Court found no compelling reason to overturn these findings. It methodically rejected the appellants’ arguments attacking the witnesses’ testimonies as contrary to human nature. The claim that the assailants should have noticed the eyewitnesses was dismissed, as the perpetrators were likely engrossed in the attack, and a gumamela plant partially obscured the view. The Court also found nothing unnatural in the witnesses’ initial silence due to fear, noting they disclosed what they saw to the victim’s wife the following day. The testimonies were deemed clear, consistent, and credible. The qualifying circumstance of treachery was sufficiently established because the attack, commenced with a sudden blow to the head while the victim was restrained, ensured he was defenseless and unable to retaliate. The penalty of reclusion perpetua was affirmed, and appellants were ordered to solidarily pay the victim’s heirs P50,000.00 as civil indemnity.