G.R. No. 214757 - People vs. Sibbu

On December 6, 2004, in Barangay Elizabeth, Municipality of Marcos, Province of Ilocos Norte, appellant Tirso Sibbu, together with co-accused Benny Barid and unidentified John Does, was charged with:

Attempted murder in Criminal Case No. 11722 – for allegedly shooting Bryan Julian y Villanueva (the private complainant) without success, as the shot missed.
Murder in Criminal Case Nos. 11721, 11723, and 11724 – for allegedly shooting and killing three victims: Trisha May Julian y Villanueva, Ofelia Julian y Bagudan (or Bayudan as later amended), and Warlito Julian y Agustin.

The crimes were committed at the residence of the victims during nighttime where disguise was employed; appellant was seen wearing a bonnet which partially covered his face and a camouflage uniform.

Bryan Julian, a key witness and the private complainant, testified that while he was with his family on the azotea, he noticed a man in camouflage with a long firearm and a bonnet.
Despite the bonnet, Bryan observed that the accused fixed the bonnet to reveal his face, enabling identification by familiarity with his build, height, and body movements.
Additional eyewitnesses (Eddie Bayudan and Warlito Julian, Jr.) corroborated witnessing gunshots and the presence of an armed man in proximity to the victims' dwelling.
Police testimonies affirmed physical evidence at the crime scene including bloodstains, spent shells, and bullet holes, and confirmed the use of a caliber .30 carbine.

The appellant denied the charges, asserting he never left the house on the night of the incident since he was tending to his sick child at his in-laws’ residence.
Testimonies from his father-in-law, mother-in-law, and a visitor (Elpidio Alay) were presented to support an alibi, contending that appellant’s whereabouts precluded his presence at the crime scene.
The defense also denied any personal acquaintance with the victim’s family and claimed he did not possess a firearm, nor did he have any motive or previous dispute with the Julian family.

On May 15, 2009, the RTC found appellant guilty beyond reasonable doubt of murder in Criminal Cases 11721, 11723, and 11724, and of attempted murder in Criminal Case 11722.
The RTC gave substantial weight to Bryan’s positive identification and testimony, while dismissing the alibi and denial defenses as weak.
The RTC not only sentenced appellant to reclusion perpetua (and specified terms for attempted murder in the separate case) but also imposed monetary awards for civil indemnity, moral, exemplary, and actual damages.

On January 6, 2014, the CA affirmed the RTC’s decision with modifications particularly to the amounts awarded for damages.
The appellate court reiterated the credibility of eyewitness identification and the evidentiary value of the testimonies and physical evidence.

Appellant elevated his case to the Supreme Court, challenging the credibility of witness identification and the application of aggravating circumstances.
The Supreme Court allowed the parties to submit supplemental briefs; however, the appellant did not file any new arguments.

Whether the trial court erred in giving undue credence to Bryan Julian’s testimony identifying appellant as the assailant.
Whether the eyewitness identification was tainted or unreliable given the conditions (nighttime, use of disguise, distance of five meters).

Whether the prosecution effectively rebutted the constitutional presumption of innocence by establishing appellant’s presence at the crime scene.
Whether the inventory and weight of circumstantial evidence were enough to hold appellant guilty beyond reasonable doubt.

Whether the trial court (and subsequently, the CA) correctly appreciated and applied the aggravating circumstances of treachery, dwelling, and disguise.
Whether the alleged absence of premeditation or intent, as argued by appellant in relation to treachery, undermined the finding of qualifying circumstances in the crimes charged.

Whether the defense of denial and alibi, supported by family testimonies, sufficiently established that appellant could not have been at the crime scene.
Whether the geographical and temporal aspects of the appellant’s claimed whereabouts negate the possibility of his involvement in the shootings.