Case Summary (G.R. No. 151021)
Factual Background
Steven Alston Davis and his long-time friend Michael Dunn were at Steven's apartment on the evening of July 17, 2002. After going to sleep, they were attacked by three men armed with handguns at approximately 2:00 AM, who invaded Steven's room and shot him four times, resulting in his death. Michael Dunn, who was present, attempted to revive Steven but was unsuccessful. Emergency responders confirmed Steven's death upon arrival.
Procedural History
Charges of murder were initially brought against Arnold Adoray and Alexander Dagami, while Evelyn Bohol was later charged for their involvement in the conspiracy to murder Steven. During the proceedings, Robin Butas testified against Evelyn, stating that she had conspired with Arnold and himself to carry out the murder. The Regional Trial Court (RTC) found Evelyn guilty of murder on November 25, 2004, sentencing her to reclusion perpetua, citing conspiracy and treachery as qualifying factors.
Appellant’s Arguments
Evelyn Bohol contended that her conviction was erroneous and that her guilt was not proven beyond a reasonable doubt. She claimed that Robin Butas's testimony should not hold weight due to his motivations as a state witness and asserted that her absence from the scene of the crime indicated her lack of direct involvement. She questioned the presence of treachery in the incident and maintained that her intentions and motives were not adequately established.
Legal Analysis of Credibility and Testimony
The Supreme Court underscored the importance of witness credibility in evaluating guilt. The appellate court affirmed the decision of the RTC based on the sufficiency and consistency of Robin Butas's testimony, which was corroborated by physical evidence—specifically, the autopsy report detailing the gunshot wounds to Steven’s body. The fact that Robin was originally charged as a co-conspirator but later became a state witness did not inherently discredit his testimony. Furthermore, the court concluded that the corroboration provided by Robin's wife, who is also Evelyn’s sister, bolstered the credibility of the testimony.
Conviction of Murder and Treachery
To constitute murder, the crime must be committed with treachery, which involves a surprise attack that deprives the victim of any opportunity to defend themselves. In this case, the attack on Steven was executed while he was asleep and defenseless. The court found that although Evelyn did not shoot Steven, her participation in the conspiracy was evident as she provided access to the apartment and encouraged the actions of the co-conspirators.
Establishing Conspiracy
Conspiracy requires proof of an agreement to commit a felony, which may be demonstrated through circumstantial evidence. The court established that Evelyn induced the assailants, provided the keys to Steven's apartment, and acted as a guide to the crime scene. Her actions before, during, and after the murder indicated a coordinated effort to execute the crime, satisfying the legal threshold for conspiracy.
Rejection of Alibi Defense
Evelyn's alibi was deemed weak given the evidence presented. The proximity of Angeles City to Makati, together w
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Case Overview
- This case concerns an appeal filed by Evelyn Bohol against the decision of the Court of Appeals (CA) which affirmed the Regional Trial Court (RTC) ruling finding her guilty of murder.
- The appellant, Evelyn Bohol, is convicted in connection with the murder of her husband, Steven Alston Davis, a British national.
Background Facts
- Steven Davis was the Chief Technology Officer of JC Software and lived in Makati City while his family resided in Angeles City, Pampanga.
- Evelyn married Steven in March 1997 when she was 17, and they had two minor children.
- On the night of July 17, 2002, after work, Steven was shot by three intruders while he slept in his apartment.
Incident Details
- Steven and his friend Michael Dunn returned to their apartment in Makati at approximately 1:00 AM.
- At about 2:00 AM, three armed men entered the apartment, shot Steven four times in the back, and fled the scene.
- Michael attempted to revive Steven but found him lifeless, and he contacted the police.
Investigation and Arrest
- Evelyn was unreachable immediately after the incident but was later informed by Michael about her husband's death.
- An autopsy revealed that Steven sustained four gunshot wounds, corroborating the violent nature of the attack.
Charges and Trial
- Arnold Adoray and Alexander Dagami were initially charged with murder, and later, Evelyn Bohol and Robin Butas were charged in conspir