Title
Marturillas vs. People
Case
G.R. No. 163217
Decision Date
Apr 18, 2006
Celestino Marturillas convicted of homicide for shooting Artemio Pantinople in 1998. SC affirmed conviction, citing credible eyewitnesses, dying declaration, and insufficient exculpatory paraffin test results. Damages modified.

Case Summary (G.R. No. 163217)

Prosecution’s factual presentation

The prosecution presented eyewitness testimony principally from the victim’s wife, Ernita, and neighbor Lito Santos, combined with the investigating officer’s report and medico-legal findings. The asserted facts: at about 6–7:30 p.m. on November 4, 1998, after Artemio had returned home and sat in front of his store, a gunshot was heard; Artemio staggered and shouted, “Help me p’re, I was shot by the captain.” Ernita testified she saw petitioner running away carrying a long firearm resembling an M-14; Lito heard the shout and saw smoke from the muzzle and Artemio collapse. Police were notified; petitioner was asked to accompany police and surrendered his M-14 rifle and was detained. Autopsy findings by Dr. Ledesma established a gunshot wound to the chest as cause of death, with trajectory and absence of powder burns indicating the shot was fired from a distance. Photographs and scene descriptions showed illumination from two fluorescent lamps and a full moon at the time.

Defense’s factual presentation and evidentiary points

Petitioner’s defense offered statements and witness testimony that he was roused from sleep by kagawads, assembled SCAA members, and proceeded toward the crime scene but left because the victim’s wife was belligerent. Petitioner voluntarily accompanied police and surrendered his government-issued M-14 rifle and submitted to paraffin testing, which returned negative for gunpowder nitrates. Defense witnesses described scene darkness and vegetation, challenged visibility, and one witness saw unidentified armed men flee but could not identify them. The police blotter initially described the assailant as “unidentified armed men.” Defense argued inconsistency between affidavits and testimony, unreliability of identification, and that the paraffin test and lack of recovered crime gun weakened the prosecution’s case.

Trial court and Court of Appeals findings

The RTC convicted petitioner for homicide. The CA affirmed the conviction, finding the prosecution witnesses credible and their testimony positive, credible, and consistent with scene conditions (illumination, familiarity of witnesses with petitioner). The CA rejected the defense alibi and denial as suspect and insufficient to overcome direct eyewitness identification and the victim’s statement. The CA also modified damages, awarding indemnity, actual damages, and other relief as supported by evidence.

Issues presented to the Supreme Court

Petitioner advanced four principal arguments: (1) miscrediting of prosecution witnesses and faulty positive identification; (2) impermissible shifting of burden to petitioner due to investigative lapses; (3) that the victim’s utterance was incomplete because death intervened, making dying declaration inapplicable; and (4) that petitioner’s alibi should prevail given alleged evidentiary gaps, including negative paraffin test and no recovered crime firearm.

Standard of review on factual findings

The Supreme Court applied the settled rule of deference: factual findings of trial courts are accorded great weight, particularly when affirmed by the CA. Disturbance of such findings requires demonstration of recognized exceptions (e.g., contradictory findings, speculation, grave abuse of discretion). The Court found no applicable exception in petitioner’s submissions and therefore began from the presumption of correctness of the lower courts’ factual findings.

Credibility and positive identification analysis

The Court analyzed Ernita’s and Lito’s accounts against scene conditions and concluded the witness identifications were reliable. Key points: (a) familiarity — Ernita knew petitioner as a neighbor and long-time barangay captain; (b) visibility — the place was illuminated by two fluorescent lamps and moonlight, and trunk/vegetation did not materially obstruct view; (c) contemporaneity — Ernita observed petitioner running away immediately after the gunshot and could describe clothing and firearm; (d) corroboration — Lito corroborated the timing and victim’s cry; (e) demeanor and lack of motive — courts found no convincing evidence that Ernita harbored ill motive to falsely accuse petitioner. The Court reiterated that conditions such as moonlight and artificial lighting can suffice for identification and that familiarity with the accused reduces the risk of misidentification.

Hearsay exceptions — dying declaration and res gestae

The Court considered the victim’s outcry, “Help me p’re, I was shot by the captain,” and held it admissible both as a dying declaration and as part of the res gestae. For dying declaration the Court applied the Rule 130 requisites: the statement related to cause and circumstances of death; it was uttered in the context of impending death (the surrounding facts and subsequent death allowed inference of consciousness of impending death); it was voluntary and offered in a prosecution for death; and the declarant was competent. For res gestae the Court found the declaration made immediately after a startling occurrence, without intervening opportunity for contrivance, and concerning the occurrence in question. The Court concluded the victim’s statement carried significant evidentiary weight as both exceptions to the hearsay rule.

Treatment of alleged inconsistencies and witness affidavits

The Court found the purported inconsistencies between affidavits and in-court testimony to be either illusory or immaterial. It explained that ex parte affidavits are often incomplete and that differences as to whether the victim was recognized by sight or voice did not undermine the identification of petitioner as the fleeing assailant. The Court emphasized trial courts’ superior opportunity to observe witness demeanor and assess credibility.

Sufficiency of evidence and circumstantial evidence framework

Assessing the totality of evidence, the Court concluded the prosecution had established guilt beyond reasonable doubt. It identified multiple proven facts: the gunshot and victim’s cry; eyewitness observations of petitioner fleeing with a rifle; the victim’s immediate accusation; corroborative statements; motive evidence (a disputed real estate transaction and antagonism); and medico-legal findings consistent with a fatal gunshot inflicted shortly after the events. The Court noted Rule 133’s standard for circumstantial evidence and affirmed that a combination of proven circumstances satisfied the requirement to produce moral certainty.

Negative paraffin test and lack of recovered crime gun

The Court addressed probative value of the negative paraffin test and the prosecution’s failure to produce the actual firearm used. It reiterated precedent that a negative paraffin test is not conclusive of non-involvement — nitrates can be absent due to gloves, handwashing, perspiration, or passage of time — and that failure to produce the weapon or laborat

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