Case Digest (G.R. No. 94530)
Facts:
This case involves the People of the Philippines as the Plaintiff-Appellee against Dante Donato and Ben Catuiran, the Accused-Appellants, in a murder case decided on March 6, 1992, by the Second Division of the Supreme Court of the Philippines. The events transpired in Amulung, Cagayan, on the night of March 24, 1980. According to the Information filed by the Provincial Fiscal, the accused-elect, along with several others, was charged with the murder of Perjulio Batarina. The prosecution's evidence established that the accused called a meeting under the pretext of discussing a land dispute, during which they attacked Batarina with the intent to kill, employing various means such as stabbing and hacking him. Witness Dominador Pascual testified that Batarina was physically assaulted by a group that included Donato and Catuiran. Following the brutal attack, Batarina was bound, further immobilizing him and leading to his eventual death from multiple stab wounds. The trial court founCase Digest (G.R. No. 94530)
Facts:
- Background of the Case
- The case involves an appeal from the decision of the trial court which found accused-appellants Dante Donato and Ben Catuiran guilty of murder.
- The prosecution charged the accused with the murder of Perjulio Batarina, an offense defined and penalized under Article 248 of the Revised Penal Code.
- The case was consolidated with other accused, but the present decision focuses on the actions of Donato and Catuiran.
- Details of the Crime
- On or about March 24, 1980, in Pacac Pequeno, Amulung, Cagayan, a meeting was convened on a lot owned by the victim, Batarina.
- Dominador Pascual, at the call of Dante Donato and Alberto Bautista, assisted in summoning people to the meeting.
- During the meeting, discussions on property grievances led to a confrontation.
- At the meeting, Batarina was brought forward and, in the presence of gathered locals, became the target of an unprovoked assault.
- Andres Balbuena, one of the ringleaders, ordered the attack.
- Batarina was mauled, chased, and eventually brought to a location near a creek in Tana.
- The assault culminated in numerous stab and cut wounds inflicted on Batarina that ultimately caused his death.
- Witness testimony and forensic findings confirmed that the victim sustained multiple fatal wounds.
- Specific acts committed include stabbing by Ben Catuiran and hacking by Dante Donato, among others.
- Evidence Presented
- Prosecution Evidence
- Testimonies of three key witnesses:
- Dominador Pascual testified regarding the sequence of assault, identifying the accused among the assailants.
- Autopsy Findings provided a detailed account of the injuries, listing multiple stab and cut wounds.
- The findings indicated wounds inflicted by both sharp and blunt instruments.
- Defense Evidence and Arguments
- Both accused filed a plea of not guilty at arraignment.
- Accused-appellants attempted to rely on defenses of denial and alibi.
- Dante Donato claimed that he was not involved and attributed the killing to a group of nine armed men.
- The defense’s arguments were countered by the trial court, which found them insufficient and uncorroborative with the physical and testimonial evidence.
- Procedural History and Assignments of Error
- Accused-appellants raised several assignments of error on appeal:
- Error in giving credence to the prosecution’s theory and disregarding the defense.
- Error in not acquitting the accused despite the alleged deficiency of the prosecution’s evidence.
- Error in the finding of criminal conspiracy among the group of assailants.
- Error in rejecting the defenses of denial and alibi.
- Despite these assertions, the trial court’s decision was supported by the overwhelming evidence showing the participation of Donato and Catuiran in the commission of the crime.
Issues:
- Sufficiency of Prosecution’s Evidence
- Whether the testimony of a single credible witness (Pascual), when corroborated by autopsy findings, is sufficient to sustain a conviction beyond reasonable doubt.
- Whether the defense’s denial and alibi could effectively counter the cumulative evidence presented by the prosecution.
- Finding of Conspiracy
- Whether the trial court correctly established that there was a concerted plan and unity of purpose among the assailants, amounting to criminal conspiracy.
- Whether the circumstantial evidence, including coordinated actions and premeditated conduct, was sufficient to infer conspiracy.
- Evaluation of Defense Claims
- Whether the trial court erred in dismissing the accused-appellants’ claims of being wrongly implicated and in failing to establish any credible alibi.
- Whether the alleged failure to receive proper weight be given to the defense evidence constitutes reversible error.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)