Facts:

The case involves accused-appellants William Fulinara y Apucada, also known as "Wally," and Antonio Bautista y Narido, also known as "Bong" or "Tony." They, along with five unidentified accomplices, were charged with kidnapping with murder in Criminal Case No. C-16013(82) at the Regional Trial Court (RTC) of Kalookan City, Branch 121. The incident occurred on June 9, 1981, in Kalookan City, Metro Manila. The Information filed against them alleged that they unlawfully took Sy Bun Tue by force and subsequently shot him, resulting in his death.

During the trial, both accused-appellants pleaded not guilty. The prosecution presented eleven witnesses, including Pedro Beltran, a security guard, and Remedios Rasonabe, who owned a carinderia near the abduction site. Beltran testified that he observed two men, later identified as Fulinara and Bautista, forcibly taking Sy Bun Tue from his car. Rasonabe corroborated this account. Later that night, Sy Bun T...

Facts:

Incident Overview:

• On June 9, 1981, in Kalookan City, Metro Manila, accused-appellants William Fulinara and Antonio Bautista, along with five other unidentified individuals, were charged with kidnapping and murdering Sy Bun Tue. The victim was forcibly taken from his car, and his body was later found in a ravine in Dinalupihan, Bataan, with multiple injuries, including a gunshot wound to the head.

Eyewitness Testimonies:

• Pedro Beltran, a security guard, testified that he witnessed the abduction. He saw two men in military uniforms (identified as Fulinara and Bautista) and two others in civilian clothes stop Sy Bun Tue’s car, force him into the backseat, and drive away in his vehicle. Beltran noted the license plate of the Toyota car used by the accused.
• Remedios Rasonabe, a carinderia owner, corroborated Beltran’s account, stating that she saw the abduction from her establishment.

Discovery of the Victim’s Body:

• On June 10, 1981, Sy Bun Tue’s body was found hogtied with an electric cord in a ravine in Bataan. A post-mortem examination revealed multiple injuries, including a gunshot wound to the head, which was determined to be the cause of death.

Apprehension of Accused:

• On August 23, 1981, Sgt. Policarpio de los Reyes of the Constabulary Highway Patrol Group (CHPG) apprehended Fulinara and Bautista in San Fernando, Pampanga, while they were in possession of Sy Bun Tue’s car. The car’s ownership was verified through its registration details.

Defense of Alibi:

• Fulinara claimed he was on a mission in Nueva Ecija at the time of the crime and that the car was lent to him by a friend, Reynaldo Baun. Bautista also claimed he was on a mission in Mariveles, Bataan, during the incident. Both presented witnesses to corroborate their alibis.

Polygraph Test:

• Fulinara underwent a polygraph test, which indicated that he was lying about his possession of the car.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Credibility of Eyewitness Testimony:

   • The Court found Pedro Beltran’s testimony credible and consistent. His identification of the accused was clear and unequivocal, despite minor inconsistencies in his description of their height. The Court ruled that the absence of a police line-up does not invalidate the identification.

2. Weakness of Alibi:

   • The Court reiterated that alibi is a weak defense, especially when the accused are positively identified by credible witnesses. The defense failed to prove that it was physically impossible for the accused to be at the scene of the crime.

3. Circumstantial Evidence:

   • The Court ruled that circumstantial evidence, such as the possession of the victim’s car by the accused and the lack of a plausible explanation for its possession, sufficiently established their guilt.

4. Treachery as a Qualifying Circumstance:

   • The Court agreed with the trial court’s finding that treachery was present, as the victim was defenseless and his hands were hogtied when he was killed.

5. Civil Indemnity:

   • The Court modified the damages awarded, reducing the funeral and burial expenses to P8,000.00 (the amount proven by the widow) and maintaining the award of P150,000.00 for moral and compensatory damages.

Conclusion:

The Supreme Court upheld the conviction of Fulinara and Bautista, emphasizing the strength of the eyewitness testimony and the circumstantial evidence against them. The Court also affirmed the penalty of Reclusion Perpetua and adjusted the civil indemnity awarded to the victim’s heirs.