G.R. No. 166441 - Cruz y Bartolome vs. People

The accused-appellants (Edwin Belibet, Manny Banoy, and Ronnie Rosero) were convicted of murder for the killing of Gracito Hatulan by Branch 47 of the Regional Trial Court of Masbate.
The murder was committed under circumstances allegedly involving premeditation, treachery, and the use of superior strength, with no mitigating circumstances to offset the aggravating factors.
The case resulted in a sentence of reclusion perpetua, a monetary indemnity to the victim’s heirs, accessory penalties, and proportionate payment of costs, with partial credit for preventive detention.

On the evening of June 3, 1987, a dance was held at Sitio Nipa, Barangay Bolo, Masbate, which was attended by the accused and Gracito Hatulan among others.
An altercation arose during the dance when Hatulan confronted Manny Banoy about a pair of pants he lost, which Banoy denied stealing.
Later during the event, witness Erusto Cos reported overhearing a discussion among Edwin Belibet, Manny Banoy, and Ronnie Rosero to kill Hatulan.
At approximately 2:00 a.m. on June 4, 1987, while passing along the seashore after leaving the dance hall, the accused encountered Hatulan sleeping in a banca.
Despite Cos’s attempt to rouse Hatulan, his companions prevented him from doing so.
The accused then executed their plan: Belibet used a machete to stab Hatulan, followed by Rosero, while Banoy restrained the victim by holding his hands.
Erusto Cos subsequently informed Hatulan's mother of his son’s demise later that same morning.

The postmortem report by Dr. Emilio C. Quemi confirmed stab wounds on the victim’s chest, consistent with the testimony regarding the use of a machete.
The testimony of prosecution star witness Erusto Cos played a central role in identifying the accused and detailing the sequence of events leading to the murder.
Testimonies from the accused regarding their alibi and denials were given, with claims of being at the dance and later going separate ways.
Physical evidence, such as the proximity of the crime scene (the seashore) to the dancing hall and the residences of the accused, was used to evaluate the credibility of the alibi defense.

An information charging the accused with murder was filed on August 11, 1987, alleging that they conspired and executed the killing with evident premeditation and treachery.
At arraignment, the accused pleaded not guilty, but the trial court eventually convicted them based on the strength of the prosecution evidence.
On appeal, the accused argued that the court erroneously relied on the testimony of Erusto Cos, alleging it to be fabricated, and contended that inconsistencies weakened the prosecution’s case.
The defense also argued that the prosecution’s evidence was insufficient to prove guilt beyond reasonable doubt, citing the weakness of the alibi and denial defenses.

Whether the prosecution presented evidence sufficient to establish the accused’s guilt beyond reasonable doubt.
Whether the incremental inconsistencies in witness testimonies, particularly those of Erusto Cos, significantly undermined the prosecution’s case.

The extent to which the credibility of prosecution star witness Erusto Cos could be challenged based on his limited education, potential inconsistencies, and alleged admission of fear of being implicated.
Whether the defense’s contention that Cos’s testimony was elicited by leading questions invalidates its weight.

Whether the accused adequately established an alibi by proving that they were at a different location during the commission of the crime.
The impact of geographic proximity between the crime scene, the dancing hall, and the residences of the accused on the viability of the alibi.

Whether the trial court abused its discretion by favoring the positive identification and detailed testimony of a lay witness over the denials and alibi asserted by the accused.
How the inherent deference to a trial court’s assessment of witness credibility plays a role in the appellate court’s evaluation of the case.