G.R. No. L-53672 - Bata Industries, Ltd. vs. Court of Appeals

The accused, Rodolfo Patawaran, a former member of the Civilian Home Defence Force (CHDF) of Tarlac, is charged with the murder of Martin Panlican.
The killing occurred on January 3, 1986, in the Municipality of Bamban, Tarlac, where Panlican, a farmer and overseer of sugarcane and rice crops, was fatally shot.
The crime was committed using an armalite rifle, with evidence indicating treachery in the way the shooting was executed.
The prosecution charged that the killing involved conspiracy and was committed with deliberate intent, treachery, and evident premeditation.

The case was first tried and decided by the Regional Trial Court of Capas, Tarlac, Branch 66, which rendered its decision on October 5, 1992.
The accused was found guilty beyond reasonable doubt of murder and was sentenced to reclusion perpetua. He was also ordered to indemnify the heirs of the deceased, pay compensatory damages for loss of earning capacity, attorney’s fees, and proportionate costs.
The prosecution presented several witnesses:

Jose Ortiz, who testified being in the vicinity and provided a detailed account of the shooting.
Engracio Dingle and Alberto Arellano corroborated the proximity of the accused to the scene.
Additional testimonies, including that of Dr. Roberto SJ Cecilio (the autopsy report confirming 13 frontal gunshot wounds) and technical/mechanical personnel, supported the narrative.

The defense relied on the accused’s and his father Conrado Patawaran’s testimonies to establish an alibi asserting that the accused was at Camp Makabulos throughout the day.
Multiple inconsistencies emerged in the defense’s account, particularly regarding:

The time of the accused’s alleged visit to Governor Federico Peralta (testimonies fluctuated between January 3 and January 4, 1986).
Discrepant accounts involving the former Bamban Mayor Pedro Mendiola regarding whether or not he accompanied the accused.

The eyewitness testimony of Jose Ortiz was presented as the cornerstone of the prosecution’s case, supported by corroborative accounts from Engracio Dingle and Alberto Arellano.
The autopsy report by Dr. Cecilio confirmed the use of a high-powered automatic firearm through the nature and number of gunshot wounds, strongly indicating treachery.
The defense’s alibi was undermined by:

Minor discrepancies noted in some testimonies were deemed non-material by the court, as they did not detract from the overall narrative identifying the accused as the assailant.

Whether the testimony of a single eyewitness (Jose Ortiz), when corroborated by other material testimonies, is sufficient to establish guilt beyond reasonable doubt.
Whether the defense’s alibi, largely based on inconsistent testimonies of the accused and his father, meets the strict requirement for proving the accused’s absence from the scene at the time of the crime.
Whether the evidence supports qualifying the crime as one committed with treachery.
Whether there was sufficient evidence to establish evident premeditation as an aggravating circumstance.
Whether the trial court erred in giving significant weight to the credibility of the prosecution’s witnesses, despite alleged inconsistencies in isolated details.