GR L 38042; (June, 1987) (Digest)
G.R. No. L-38042. June 30, 1987.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PEDRO ALCANTARA and MANUEL GUINTO, accused, MANUEL GUINTO, accused-appellant.
FACTS
The case involves the murder of Felipe Avendano during a benefit dance in Barrio Enriqueta, Lavezares, Samar, on June 29, 1963. The prosecution’s evidence, primarily from the victim’s two children who witnessed the event, established that Avendano was attacked from behind by three men. Accused-appellant Manuel Guinto allegedly struck the first and fatal blow with a bolo to the victim’s head, followed immediately by Pedro Alcantara who hacked the shoulder. The third assailant, Enrique Cagsawa, fled with the others after being deterred by the children’s screams. Guinto was convicted as a co-conspirator and sentenced to reclusion perpetua.
Guinto denied involvement, claiming he was among those who attended to the corpse and even retrieved a knife from the victim’s hand. He argued that the eyewitness, Lydia Avendano, gave inconsistent statements, initially claiming Alcantara delivered both blows but later testifying Guinto struck first. The defense presented two municipal officials to corroborate Guinto’s alibi. The trial court, however, found the prosecution witnesses credible, noting Guinto’s flight after the incident, as evidenced by unserved arrest warrants stating he had gone to Manila.
ISSUE
Whether the guilt of accused-appellant Manuel Guinto for the crime of murder was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, finding no abuse of discretion. The inconsistency in Lydia Avendano’s sworn statement, made merely four days post-trauma, did not destroy her overall credibility; affidavits are often incomplete and inaccurate. Her testimony was corroborated by her brother on all material points. The defense witnesses’ testimonies were outweighed by the positive identification from the Avendano children, who had no ill motive to falsely accuse Guinto.
The Court found Guinto’s flight indicative of guilt, as he could not be located for a decade despite warrants, contradicting his claim of continuous residence. The collective evidence established conspiracy and treachery (attack from behind without warning), qualifying the killing as murder. With no aggravating or mitigating circumstances, the penalty of reclusion perpetua was proper. The civil indemnity was increased to P30,000.00. The judgment was affirmed with modification.