Case Summary (G.R. No. 91260)
Conviction Background and Sentencing
The Regional Trial Court held that the prosecution established the guilt of the accused beyond a reasonable doubt, attributing the crime to the presence of treachery and the superior strength employed by the assailants. The accused were sentenced to reclusion perpetua, ordered to pay indemnity of P30,000 to the heirs of the victim, and credited with four-fifths of their preventive imprisonment.
Incident Summary and Evidence
The assault on Gracito Hatulan occurred in the early hours of June 4, 1987. After expressing dissatisfaction over lost property at the dance, a plan to kill the victim was allegedly hatched by the accused. Subsequently, they attacked Hatulan while he was asleep in a boat, inflicting fatal stab wounds. The postmortem report confirmed the cause of death due to the injuries sustained.
Procedural History and Appeal Grounds
An information was filed against the appellants based on the murder committed, alleging conspiracy and intent with treachery and superiority in strength. Following their arraignment with a plea of not guilty, the appellants challenged their conviction, asserting that the trial court erred in relying on the testimony of Erusto Cos, which they claimed was fabricated and insufficient to prove their guilt beyond reasonable doubt.
Evaluation of Evidence and Witness Credibility
The review focused on the sufficiency of evidence to confirm the appellants’ guilt. Established jurisprudence dictates that the appellate court respects the trial court's findings regarding witness credibility. The defense's claims that Cos's testimony was inconsistent were unfounded, as the court noted that minor discrepancies do not detract from the overall reliability of a witness’s account. Cos's testimony aligned with the forensic evidence, and there was no evidence indicating that he had any motive to fabricate his claims against the appellants.
Defense Credibility and Witness Reliability
Despite the appellants’ denials, their claims were undermined by Cos’s positive identification of them as the perpetrators. The court underscored that denials and alibis are generally weak defenses when weighed against credible positive testimonies. Alibi defenses were particularly unconvincing given the proximity of the crime scene to where the accused claimed to have been at the time of the incident.
Confirmation of Trial Court's Judgment
The
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Case Background
- The accused-appellants, Edwin Belibet, Manny Banoy, and Ronnie Rosero, were convicted of murder by Branch 47 of the Regional Trial Court of Masbate for the killing of Gracito Hatulan.
- They appealed the conviction, asserting their innocence and claiming that the trial court's decision was erroneous.
- The trial court's ruling, issued on September 14, 1989, established that the prosecution had sufficiently proven their guilt, highlighting the use of superior strength and treachery in the commission of the crime.
- The court sentenced each accused to reclusion perpetua, ordered them to indemnify the victim's heirs with P30,000.00, and imposed accessory penalties and costs.
Factual Antecedents
- On June 3, 1987, during a dance at Sitio Nipa, Barangay Bolo, Masbate, Gracito Hatulan confronted Manny Banoy regarding a pair of pants he claimed were stolen by Banoy.
- Following this confrontation, a plan to kill Gracito Hatulan was allegedly discussed by Edwin Belibet, Manny Banoy, and Ronnie Rosero, overheard by a witness, Erusto Cos.
- In the early hours of June 4, 1987, the accused left the dance hall and found Gracito sleeping in a banca (small boat).
- Edwin Belibet attacked Gracito with a machete, followed by Ronnie Rosero, while Manny Banoy restrained the victim.
- Erusto Cos, who was present, attempted to intervene but ultimately fled in fear.
Evidence Presented
- The autopsy conducted by Dr. Emilio C. Quemi revealed t