GR L 49069; (June, 1983) (Digest)
G.R. No. L-49069. June 22, 1983.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PROTACIO AMONCIO and FLORENCIO VALLESPIN, accused-appellants.
FACTS
Accused Protacio Amoncio and Florencio Vallespin were charged with Murder for the killing of Vicente Vallespin on June 12, 1976, in Mabini, Bohol. The prosecution’s version, primarily through the testimony of the victim’s son, Leopoldo, was that the accused conspired and waylaid the victim. They ambushed him while he was untying his carabao, with Amoncio striking the back of his head with a piece of wood and Vallespin hacking him with a bolo. The body was subsequently dragged to a bamboo grove. The defense presented a截然不同的 account, alleging that Amoncio arrived home to find the deceased attempting to rape his wife inside their house. Amoncio claimed he then hacked the deceased in defense of his spouse, after which the victim fled and died nearby.
The trial court found the accused guilty of Murder, sentencing each to Reclusion Perpetua and ordering them to indemnify the heirs. The accused appealed, challenging the trial court’s factual findings and credibility assessments.
ISSUE
The core issue is whether the trial court erred in convicting the accused of Murder by giving credence to the prosecution’s evidence over the defense’s theory of justification.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s factual findings, emphasizing the well-settled doctrine that trial courts’ assessments of witness credibility are accorded great weight and respect, as they have the direct opportunity to observe the witnesses’ demeanor, sincerity, and manner of testifying. The trial court found the prosecution’s star witness, Leopoldo Vallespin, to be credible and sincere, with his material assertions corroborated by subsequent findings.
The defense’s theory of an attempted rape justifying the killing was thoroughly discredited. The medical certificate for Bibiana Amoncio, the alleged victim of the rape attempt, showed only a minor contusion on her knee and complaints of neck pain, with no findings whatsoever to substantiate a violent sexual assault. Crucially, the medical evidence for the deceased, Vicente Vallespin, completely contradicted the defense narrative. The victim sustained eleven wounds, including multiple deep stab and incised wounds to the neck, chest, and back, and a contusion on the occiput. The physician testified these wounds were inflicted by more than one instrument and in more than one manner, inconsistent with a sudden, close-quarters altercation inside a house. The nature, number, and location of the wounds supported the prosecution’s theory of a concerted attack with treachery. The Supreme Court found no reason to overturn the trial court’s conclusion that the prosecution proved the guilt of the accused beyond reasonable doubt.
