GR L 59217; (April, 1984) (Digest)
G.R. No. L-59217 April 30, 1984
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ILARDE ITURA, defendant-appellant.
FACTS
The case originated from the killing of Felix Renacido on May 13, 1975, in Barrio Catabana, Madalag, Aklan. Accused Ilarde Itura, along with Crispin Naelga and later Rafael Sailog, were charged with Murder. The prosecution evidence established that Itura was the first to attack Renacido with a fighting bolo, followed by Naelga, and Sailog with an ax. The victim sustained seven fatal wounds. During trial, co-accused Crispin Naelga withdrew his not guilty plea and pleaded guilty to the lesser offense of Homicide, for which he was separately sentenced. Trial proceeded solely against appellant Itura.
The defense of Itura was alibi, claiming he was elsewhere during the incident. He challenged the credibility of the prosecution’s eyewitnesses, Porferio Mirano and Rafael Sailog, arguing their failure to immediately report the crime to police authorities rendered their testimonies dubious. The trial court convicted Itura of Murder, qualified by treachery, and sentenced him to reclusion perpetua with damages. Itura appealed the decision.
ISSUE
The core issue is whether the trial court erred in convicting appellant Ilarde Itura of Murder based on the credibility of the prosecution witnesses and in finding the qualifying circumstance of treachery.
RULING
The Supreme Court affirmed the conviction. On the credibility of witnesses, the Court held that the delay in reporting the incident, as explained by eyewitness Porferio Mirano, did not impair their credibility. Mirano testified they deferred reporting to await the arrival of the victim’s children from Manila. The Court emphasized that the assessment of witness credibility is best left to the trial court, which observed their demeanor, and found no compelling reason to overturn its findings. The positive identification by eyewitnesses prevailed over Itura’s weak alibi.
Regarding the nature of the crime, the Court upheld the finding of Murder qualified by treachery. The attack on Renacido was sudden and unexpected, rendering him entirely defenseless and ensuring the execution of the killing without risk to the assailants. However, the Court found that conspiracy and evident premeditation were not sufficiently proven. The award for damages was modified, consolidating various indemnities into a single death indemnity of Thirty Thousand Pesos (P30,000.00). The judgment of conviction was thus affirmed with this modification.