Case Summary (G.R. No. 128617)
Summary of Facts
On March 19, 1995, at approximately 6:45 PM, in Cebu City, Cesar Bacus shot and killed Roel Sabejon using a deadly weapon. The incident occurred outside a billiard hall, witnessed by several individuals, including Fe Claros, Roel's sister. Claros testified that she heard gunshots and observed Bacus firing at her brother from behind. Other witnesses included Giovanni Mantalaba, a nephew of the victim, and Francisca Sabejon, the victim's mother, both of whom corroborated the prosecution’s account of events leading to the shooting. Upon arrival at the crime scene, police officers located Bacus near his mother-in-law’s house, where he was allegedly attempting to evade arrest.
Prosecution Evidence
The prosecution presented eyewitness accounts, including detailed testimonies from Claros, Mantalaba, and Sabejon, consolidating the narrative that Bacus intentionally targeted Roel. Forensic evidence provided by Dr. Nestor Sator revealed that the fatal gunshot wounds were inflicted at close range, corroborating eyewitness testimonies. Claros's account was particularly significant, as she not only described the sequence of events leading up to the shooting but also positively identified Bacus as the shooter, despite the defense's contention that the eyewitnesses were biased due to their familial connection to the victim.
Defense Strategy
In Bacus’s defense, five witnesses testified to establish his alibi, claiming he was at home at the time of the crime. Bacus argued that the prosecution's case relied on the testimony of biased relatives. He sought to undermine the credibility of the prosecution's witnesses, particularly focusing on perceived inconsistencies in their accounts and the alleged failure to substantiate claims regarding his escape attempts.
Court's Findings on Credibility
The trial court dismissed the defense's challenges to the credibility of the prosecution witnesses. It affirmed that familial ties do not inherently bias eyewitness testimony and highlighted the consistency, clarity, and detail of Claros's account. The court determined that minor inconsistencies in witness testimonies did not detract from their overall credibility, and it emphasized that credible eyewitness accounts, especially from those closely related to the victim, can significantly bolster the prosecution's case.
Legal Conclusions on Guilt
The court found the evidence sufficient to establish guilt beyond reasonable doubt. It held that the crime was committed with treachery, as Bacus ambushed Roel from behind, rendering him defenseless. The trial court ruled that the prosecution met its burden of proof, establishing Bacus's responsibility for the murder.
Sentencing and Civil Liabilities
Bacus was sentenced to the penalty of reclusion perpetua and ordered to compensate the heirs of Roel Sabejon with P50,000.00 in civil indemnity and an additional P6,000.00 as actual damages for funeral expenses. The trial court's decision also reflected a prevailing doctrine that civil indemnity does not need to be proven but is awarded as a matter of course in ca
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Background of the Case
- This case originates from an appeal against the decision rendered on September 26, 1996, by the Regional Trial Court, Branch 57, Cebu City.
- The accused-appellant, Cesar Bacus, was found guilty of murder and sentenced to reclusion perpetua.
- He was also ordered to pay the heirs of the victim, Roel Sabejon, P50,000.00 as indemnity and P6,000.00 as actual damages.
Incident Details
- The incident occurred on March 19, 1995, around 6:45 PM in Cebu City.
- The information charged that Bacus, armed with a deadly weapon, attacked and shot Roel Sabejon multiple times with intent to kill, exhibiting treachery and evident premeditation.
Prosecution's Evidence
- The prosecution presented five witnesses, three of whom claimed to be eyewitnesses to the shooting.
- Fe Claros, the victim's elder sister, testified that she heard gunshots and saw Bacus shooting her brother from behind. She described Bacus pointing his gun at the victim and repeatedly pulling the trigger.
- Giovanni Mantalaba, a 12-year-old nephew of the victim, testified that he saw Bacus shoot Sabejon after seeing Bacus walk towards Peace Valley with another individual.
- Francisca Sabejon, the victim's mother, recounted seeing Bacus shoot her son twice before he was taken to the hospital, where he died shortly after.
- SPO2 Godofredo Cimafranca, a police officer, testified about the arrest of Bacus and the discovery of clothing in the bag he was carrying, contradicting Bacus's claim that it contained waste matter.
- Dr. Nestor Sator, the Medico Legal Officer, conducted an autopsy revealing two fatal gunshot wounds on the victim, co