Case Digest (G.R. No. 180169)
Facts:
The case involves Agustino Tamolon and Antonio Cabagan, who were charged with Multiple Murder in Criminal Case No. XXI-377 (93) before the Regional Trial Court (RTC), Branch 21, in Bansalan, Davao del Sur. The incident occurred on March 15, 1984, in the Municipality of Magsaysay, Davao del Sur, where the accused, along with several others, allegedly attacked the Malabarbas family, resulting in the deaths of Jaime Malabarbas, Ely Malabarbas, Judith Malabarbas, Wilfredo Panton, and Gerry Panton. The prosecution's evidence indicated that the accused were armed with guns and bolos and acted in concert to carry out the attack.
During the trial, the appellants pleaded not guilty. The prosecution presented a witness, Modesto Landas, who testified that he was part of the group that attacked the Malabarbas family. The defense, however, argued that the testimony of Landas was fabricated and motivated by a desire to reduce his own legal troubles, as he had been arrested and detai...
Case Digest (G.R. No. 180169)
Facts:
Background of the Case
- The appellants, Agustino Tamolon and Antonio Cabagan, along with several others, were charged with Multiple Murder under Criminal Case No. XXI-377 (93) before the Regional Trial Court (RTC) of Davao del Sur.
- The crime occurred in March 1984 in Sitio Maibu, Magsaysay, Davao del Sur. The victims were members of the Malabarbas family and the Panton family: Jaime Malabarbas, Ely Malabarbas, Judith Malabarbas, Wilfredo Panton, and Gerry Panton.
- The appellants were accused of conspiring with others, armed with guns and bolos, to attack and massacre the victims, resulting in their deaths.
Prosecution's Version
- The prosecution presented evidence that on March 15, 1984, at around 8:00 p.m., a group including the appellants and Modesto Landas conducted a roving patrol. Upon reaching the Malabarbas family's house, they opened fire and hacked the victims, leading to their deaths.
- Modesto Landas, a co-conspirator, testified against the appellants, implicating them in the massacre.
Defense's Version
- Agustino Tamolon claimed he was in Santa Felomina, Makilala, North Cotabato, at the time of the massacre, working as a farmer and honey gatherer. He denied knowing the Malabarbas family or participating in the crime.
- Antonio Cabagan also denied involvement, stating he was arrested in 1993 and was pressured by Vilma Ganad and Antonio Malabarbas to testify against others in exchange for his release.
- Defense witnesses, including Barangay Captain Gregorio Sumakbang and Pastor Sungkadan Amit, testified that the appellants were not linked to the massacre until 1993 and that Landas testified against them to secure his own release.
Trial Court Decision
- On February 12, 1996, the RTC convicted the appellants of Multiple Murder, sentencing each to Reclusion Perpetua for each victim and ordering them to pay P50,000.00 in indemnity to the heirs of each victim.
- The case was elevated to the Supreme Court for automatic review but was referred to the Court of Appeals (CA) following the ruling in People v. Mateo.
Court of Appeals Decision
- On August 23, 2007, the CA affirmed the RTC's decision but modified the damages, ordering the appellants to pay an additional P50,000.00 as moral damages to the heirs of each victim.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Credibility of Witnesses:
- The trial court's assessment of witness credibility is entitled to great weight, especially when affirmed by the CA. Modesto Landas' testimony was deemed credible as it was given in a clear, positive, and convincing manner.
- The doctrine that a co-conspirator's testimony, even if uncorroborated, can suffice for conviction if it is sincere and detailed, was applied.
Defenses of Denial and Alibi:
- Denial and alibi are inherently weak defenses and cannot prevail over positive identification by a credible witness.
- The appellants failed to prove that it was physically impossible for them to be at the crime scene at the time of the massacre.
Award of Damages:
- Moral damages are warranted in cases of violent death, as the emotional suffering of the victims' families is inherent and undeniable, even without specific proof.