Case Digest (G.R. No. 140404)
Facts:
People of the Philippines prosecuted Bonifacio Aliben, Diosdado Nicolas and Ronnie Nicolas for the October 5, 1997 killing of Juanito P. Bongon, Sr. in Barangay Siba-o, Calabanga, Camarines Sur; the Regional Trial Court found the three guilty of murder and sentenced them to reclusion perpetua, and the defendants appealed. Eyewitnesses testified to seeing the three attack the victim with a bolo and pieces of wood; the victim allegedly made a dying declaration naming Dado and Ronnie; autopsy showed fatal skull fractures and an incised wound.
Issues:
- Were the appellants properly identified and were the prosecution eyewitnesses credible?
- Was the victim’s dying declaration admissible?
- Did the evidence show that more than one instrument was used to inflict the injuries?
- Was there proof of conspiracy among the accused?
- Was self-defense established by Ronnie Nicolas?
- Did the defenses of denial and alibi overcome the positive identifications?
Ruling:
The Court affirmed the RTC Decision convicting Bonifacio Aliben, Diosdado Nicolas and Ronnie Nicolas of murder and imposing reclusion perpetua on each; it upheld the awards of actual and civil damages, increased moral damages to P50,000.00, and added exemplary damages of P25,000.00. The Court found voluntary surrender a mitigating circumstance for Ronnie but nevertheless affirmed his conviction.
Ratio:
The Court gave weight to the trial court’s credibility findings, noting the eyewitnesses’ positive, consistent identifications and their corroboration by other witnesses and the autopsy, and declined to disturb those findings absent clear error. The dying declaration satisfied the requisites for admissibility. Medical findings showing blunt-force fractures and an incised wound supported the conclusion that more than one instrument was used. Concerted action by the accused and their failure to prevent the assault permitted inference of conspiracy, and the nature and number of wounds plus continuation of the attack after the victim was incapacitated negated self-defense. The disparity in numbers, armament, and ages supported the aggravating circumstance of taking advantage of superior strength under Article 248, and Article 63 warranted mitigation for voluntary surrender.
Doctrine:
- Trial court findings on witness credibility will not be disturbed on appeal absent clear showing of overlooked or misapplied material facts.
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