G.R. No. 94702 - People vs. Acuna

The case involves the People of the Philippines as plaintiff-appellee and the appellants, Jesus Ramos and Antonio (Tony) Dionisio, charged with murder.
Carlito Acuna was also named in the information, though he remains at large.
It is charged that on or about November 22, 1988, the accused conspired to kill Tranquilino Mariano.

On November 20 and 21, 1988, Acuna, Ramos, and Dionisio visited the house of Mariano in Pungo, Calumpit, Bulacan.
Mariano declined their invitation on both occasions.

Acuna, Ramos, and Dionisio returned to Mariano’s house in the evening.
Acuna obtained permission from Virginia Mariano (the victim’s wife) for Mariano to accompany them.
Mariano left the house with the trio while Virginia went to sleep.

Eyewitnesses Victoria Magana and Luisa Blanco, while riding a jeepney, saw from a short distance that Ramos, Acuna, Dionisio, and Mariano were quarrelling beside Ramos’ house.
They observed Acuna striking Mariano’s head with a “dos por dos” piece of wood while Ramos and Dionisio held the victim’s hands.
As Mariano fell, all three, armed with bladed instruments, took turns stabbing him.
Later, witness Precy Bautista saw Ramos, Dionisio, and another individual dragging what was later identified as Mariano’s body.

Mariano’s body was discovered by an unidentified person and subjected to autopsy by Dr. Juanito B. Sacdalan.
Autopsy findings indicated twelve stab wounds (six on the front and six on the back) and a hematoma on the left eye, possibly from a blunt blow.
Dr. Sacdalan noted that the victim died due to multiple stab wounds, punctured lungs, and a cut carotid artery.

Ramos and Dionisio were arrested on April 17, 1989, and shortly thereafter filed a motion for bail which was denied on June 1, 1989.
They were arraigned on June 28, 1989, where they pleaded not guilty.
Evidence and testimonies, including that of Virginia Mariano and the autopsy report, were presented leading up to the trial on the merits.

On May 22, 1990, the Regional Trial Court of Malolos, Bulacan, convicted Ramos and Dionisio of murder under Article 248 of the Revised Penal Code.
The case primarily hinged on the credibility and consistency of the prosecution’s eyewitness testimonies.

Whether the inconsistencies noted—such as the spatial relationship between the eyewitnesses and the accused during the commission of the crime—undermine the overall credibility of the prosecution witnesses.
The alleged contradiction between the testimony regarding the victim’s position and the autopsy findings, specifically the presence of stab wounds on both the front and back of the victim’s body versus the eyewitness account of him falling and being assaulted post-fall.
The impact of delayed reportage by prosecution witnesses, particularly the six-month delay in Precy Bautista’s testimony, on their credibility.

Whether the negative evidence (mere denials by the appellants) can outweigh the numerous affirmative testimonies of the prosecution witnesses.
The legal principle that an affirmative, affirmative testimony (even with minor discrepancies) carries greater evidentiary weight compared to self-serving negative evidence by the accused.

Whether the trial court’s assessment of the witnesses’ credibility, having observed their demeanor and manner of testifying, should be disturbed on appeal.
If any overlooked facts in the evaluation of witness credibility would have affected the outcome of the trial.