G.R. No. 177356 - People vs. Amodia y Baba

On June 10, 2003, at about 3:00 a.m. in Quezon City, an assault occurred near the Nognog Videoke Restaurant.
Richard Avila Roda, the assistant manager of the restaurant, witnessed a violent encounter involving a group of seven individuals.

Roda observed the victim being brutally mauled by the group.
Among the assailants were three regular customers later identified as accused-appellants: Johbert Amodia y Baba, Mario Marino y Patnon, and Roy Lo-oc y Pendang.
Specific actions noted included:

After the assault, the accused-appellants retreated into the restaurant and consumed beer.

The victim, later identified as Jaime Bartina, suffered serious head injuries after falling onto a concrete fence.
Despite his injuries and visible bleeding, Bartina was initially found alive but later died around 5:00 p.m. on the same day.
Cornelia Bartina, the victim’s live-in partner, discovered him at the hospital with evident signs of trauma.

Roda delayed reporting the incident immediately due to threats from the accused-appellants, who still lingered near the scene.
On June 12, 2003, Roda, upon the advice of a police member, reported the incident at Camp Karingal, which led to the filing of an Information charging the accused with murder.
The Information charged the accused with conspiracy, premeditation, and the use of undue advantage of superior strength in the commission of the crime.

The accused-appellants pleaded not guilty, denying their involvement in the crime.
Roy Lo-oc claimed that after leaving Abdul Videoke Bar—where he had been drinking following personal troubles—he encountered a man wounded and bleeding, and attempted to seek help by involving two pedicab drivers, Amodia and Marino, who refused his request.
Amodia and Marino corroborated Lo-oc’s version, maintaining their non-participation in the crime.

The Quezon City Regional Trial Court found all accused guilty of murder beyond reasonable doubt.
Special consideration was given to Johbert Amodia as he was a minor at the time; he was sentenced under mitigating circumstances to a lesser penalty (reclusion temporal) compared to the others (reclusion perpetua).
The trial court also ordered the accused-appellants to jointly and severally pay actual damages and indemnity to the victim’s heirs.

The Court of Appeals affirmed the trial court’s decision, giving significant weight to the positive and consistent testimony of the prosecution eyewitness.
The CA dismissed the accused-appellants’ denial and alibi defenses, noting that their admission of being present at the scene weakened their defense.
It was highlighted that while the accused-appellants’ non-flight was noted, it did not qualify as evidence of innocence.

Whether the court erroneously gave full credence to the eyewitness testimony, despite the delay in reporting the incident.
Whether the alleged delay, caused by threats from the accused, diminished the reliability of the witness’s account.

Whether the trial court erred in convicting the accused-appellants beyond reasonable doubt, considering their denial and alibi.
Whether the evidence presented was adequate to establish the guilt of the accused-appellants.

Whether the killing should be classified as murder or homicide, particularly in relation to the qualification of abuse of superior strength.
Whether there was clear and convincing evidence to substantiate the qualifying circumstance of abuse of superior strength by the accused-appellants.