G.R. No. 188710 - People vs. Watamama

The case involves the People of the Philippines as the plaintiff-appellee and the accused-appellant Matimanay Watamama, also known as Akmad Salipada.
Co-accused Teng Midtimbang (at large) was similarly charged under an Information for murder, docketed as Criminal Case No. 99-06.
Upon arraignment, the accused pleaded not guilty, and the charges centered on the killing of Abubakar Calim.

On the morning of October 26, 1998, witnesses reported that Francisco Arobo, Jr. (Arobo), Calim, and five other farmers were engaged in farm work at Ali Samad’s property in Sitio Matingao, Malapag, Carmen, Cotabato.
While ploughing an unplanted area, Arobo and the others heard multiple gunshots; Arobo observed that the gunfire came from behind, noting that appellant and co-accused Teng Midtimbang were firing garand rifles.
Both assailants were positioned about ten meters apart and approximately five meters obliquely behind Calim.
The sudden gunshots prompted Arobo and the other farmers to scatter for cover, while Samad, who was tending his corn, ran to seek refuge where his children were located.

Eyewitness testimony by Arobo detailed the positions of the accused as they fired at Calim and at Samad, though Samad fortunately escaped injury.
The postmortem examination revealed that Calim sustained multiple gunshot wounds in distinct parts of the body (head, chest, thighs, and right elbow).
Testimonies by other prosecution witnesses positively identified the appellant (Matimanay Watamama) as one of the persons who fired at Calim.
Despite minor discrepancies in details (for example, differences in the description of assailant positions), the overall accounts of the eyewitnesses corroborated the presence of both accused at the scene.

The appellant maintained that he was a victim of mistaken identity, asserting that his real name was Akmad Salipada and that he was wrongly identified as Matimanay Watamama.
He testified that on the morning of October 26, 1998, he was at his residence in Sitio Maitum, Malapag, Carmen, having breakfast with his wife, Guianila Salipada, and that he did not participate in the crime.
Guianila reportedly witnessed the arrival of two men (allegedly the Midtimbang brothers) near their house and heard their conversation regarding Calim.
Zaid Tayuan, a detention prisoner, testified for the defense that he observed the Midtimbang brothers commit the killing, and he contended that the appellant was not present.
However, on cross-examination, Tayuan acknowledged geographical discrepancies, including the fact that his farm was approximately five kilometers away from Sitio Matingao.

The Regional Trial Court (RTC) found the appellant guilty beyond reasonable doubt of murder, noting that the evidence, including eyewitness identifications, negated his claim of mistaken identity.
The RTC observed evident premeditation and treachery in the execution of the crime, given the calculated positioning of the accused and the sudden attack that left the victim with no chance to defend himself.
The RTC ordered the appellant to indemnify the heirs of Calim in the amount of P50,000 and imposed the penalty of reclusion perpetua along with its accessory penalties.
The Court of Appeals (CA) affirmed the conviction for murder but modified the findings regarding evident premeditation.
Furthermore, the CA increased the damages to include P50,000 as moral damages in addition to the civil indemnity awarded by the RTC, while sustaining the overall credibility of the eyewitness testimonies.

Whether the prosecution was able to prove beyond reasonable doubt the appellant's participation in the killing of Abubakar Calim.

The appellant argued that the testimonies identifying him were unreliable, being based on perceptions formed in fear and tension.
He also contended that his physical resemblance to his co-accused led to mistaken identity.

Whether the evidence presented was sufficient to establish the qualifying circumstances of treachery and evident premeditation.

The defense maintained that no eyewitness could definitively establish how the attack on Calim commenced.
The appellant argued that the alleged suddenness of the attack did not suffice to qualify the killing as treacherous.

Whether the trial court and the Court of Appeals appropriately appreciated the testimonies of both prosecution and defense witnesses.

The appellant asserted that his defense and alibi were improperly disregarded by the courts.
The issue thus revolved around the reliability and sufficiency of the identification evidence presented by the prosecution.