Title
People vs. Collamat
Case
G.R. No. 218200
Decision Date
Aug 15, 2018
Jeffrey Collamat convicted of murder for stabbing Esmeralda Gelido; treachery proven, alibi rejected, damages awarded.
murder case
stabbing death
damages awarded
A

Case Summary (G.R. No. 218200)

Charged Offense and Material Allegations in the Information

The Information, dated May 10, 2002, charged that appellant and his co-accused, mutually helping one another and acting with deliberate intent to kill, treachery, and evident premeditation, willfully, unlawfully and feloniously attacked and stabbed Esmeralda Gelido with the use of an ice pick. It further specified the medical consequences as hemorrhage from multiple punctured wounds in the right and left clavicular areas and the right chest, and it alleged that these injuries caused the victim’s instantaneous death.

Procedural History and Plea

At the time of arraignment on July 5, 2002, appellant entered a plea of not guilty. After trial, the RTC rendered a Judgment dated July 3, 2012, finding appellant guilty beyond reasonable doubt of murder under Article 248 of the Revised Penal Code. Appellant then appealed to the CA. On December 12, 2014, the CA affirmed with modification, increasing the awards by ordering appellant to pay the heirs of the victim P30,000.00 as exemplary damages in addition to the RTC’s awards.

Prosecution’s Version of the Incident

The prosecution presented a narrative centered on the confrontation between the appellant’s group and the victim’s group at Analyn’s Store in Simborio, Liloan, Cebu. On January 13, 2002, around 4:00 p.m., Benido Jumao-as (Benido) and the victim were having a drinking spree at Analyn’s Store when Benido accidentally spilled beer on appellant’s table. Appellant, at the time, was also drinking with Jimbo, Ronilo, and several others. The spilled beer led to a fistfight between the two parties. Ramon Judaya (Ramon) intervened, pacified both sides, and even offered a bottle of beer to appellant’s group as goodwill.

At around 6:30 p.m., Benido and the victim left the store. Benido testified that as they walked along the national highway, he saw the victim being attacked by four persons whom he later identified as those from the earlier altercation. Benido stated that appellant held the victim on the right side, Ronilo held the victim on the left side, and an unidentified person held the victim’s feet. Benido witnessed Jimbo stab the victim with an ice pick. Fearing for his life, Benido ran to seek shelter at Ramon’s house.

The following day, Dr. Jesus Cerna conducted an autopsy. The prosecution anchored the cause of death on the post-mortem findings that the victim sustained five stab wounds, and that the immediate cause of death was massive hemorrhage secondary to multiple punctured wounds in the right chest and the right and left clavicular areas.

Defense’s Version and Theory

Appellant denied participation in the killing. He testified that on January 13, 2002, around 3:00 p.m., he and companions were singing at the videoke in Analyn’s Store in Simborio. He named several companions, including Ronilo Rondina, Benjie Marianito, Junry Collamat, Armando Solitano, and Elmo Dela Pena. He claimed they arrived around 3:00 p.m., that there were other customers, and that they finished drinking around 7:00 p.m. He testified that they consumed one and a half cases of beer grande. He stated that Benido arrived with Esmeralda at about 3:30 p.m., that both drank redhorse beer, and that a verbal altercation occurred between Benjie Marianito and Benido after Benido toppled Benjie’s glass, which Ramon later patched up. Appellant asserted that he left at around 7:00 p.m., went to his cousin’s place in Opao, Mandaue City, and stayed for the night. In the morning, he claimed he was arrested as a suspect connected to the killing in Simborio.

Trial Court Proceedings and Ruling

The RTC credited Benido’s testimony in full. It treated Benido’s identification as positive and straightforward, and it rejected appellant’s denial. The RTC found that the prosecution’s evidence established appellant’s presence among the perpetrators and his participation in the stabbing incident. It also determined that the killing was attended by treachery, explaining that the victim was deprived of any chance to defend himself due to the suddenness of the attack and the manner by which appellant and co-accused held the victim in place while the actual stabbing was delivered by Jimbo.

On the basis of its findings, the RTC sentenced appellant to reclusion perpetua. It also ordered appellant to pay the heirs of the victim P50,000.00 as moral damages and P25,000.00 as temperate damages.

Arguments on Appeal

On further review before the CA, appellant challenged the conviction on two primary fronts: whether his identity as one of the perpetrators was proven beyond reasonable doubt, and whether treachery qualified the killing.

On review before the Court, appellant reiterated those issues. He maintained that his identity was not sufficiently established. He also disputed the presence of treachery as a qualifying circumstance.

CA’s Disposition and Modification

The CA affirmed the RTC’s determination that appellant was clearly identified as a perpetrator. It relied on the timeline of the events to support the reliability of the identification: the assailants and the victim’s group both drank and sang at Analyn’s Videoke Store; although there had been an altercation, it was pacified and appellant’s group even received a round of beer offered to appease them. The CA reasoned that the drinking ended past six o’clock, leaving an interval of about three hours before the stabbing. It concluded that the time interval was sufficient for Benido to recognize appellant’s group as among those who followed the victim after leaving the store. The CA further noted that Benido left the store with the victim ahead of appellant’s group and even bid the other group good-bye, reinforcing the plausibility of recognition.

With respect to treachery, the CA agreed with the RTC that the manner of execution afforded the victim no opportunity to escape or retaliate. It emphasized that the stabbing was committed in a manner reflecting execution designed to ensure the assailants’ advantage.

The CA modified the RTC’s damages award by directing appellant to pay P30,000.00 as exemplary damages in addition to the RTC awards.

The Court’s Evaluation: Credibility and Identification

The Court held that the appeal lacked merit and sustained the factual findings of the RTC as affirmed by the CA. It invoked the principle that when the issue hinges on the credibility of witnesses, appellate courts accord the highest respect to the trial court’s assessment, given its unique opportunity to observe witnesses’ demeanor and conduct.

Applying this standard, the Court found no showing that the lower courts overlooked, misunderstood, or misapplied facts or circumstances of weight that could have affected the result. It specifically stressed that Benido “never wavered” in his identification of appellant as one of the perpetrators. The Court quoted Benido’s direct testimony where Benido acknowledged he knew only four persons in the assailants’ group and pointed to Jimbo Saladaga and Jeffrey Collamat in court. Benido also stated that Jimbo stabbed the companion while the others held the victim, and he identified appellant as one of the persons who held the victim. The Court further noted that even during cross-examination, Benido denied the possibility of mistake on the ground that it was dark, reiterating that he had clearly seen the assailants. The Court therefore held that appellant’s defenses of alibi and denial could not prevail, since they were inherently weak against sufficient and positive prosecution identification.

The Court’s Evaluation of Treachery

On treachery, the Court agreed with the CA’s conclusion that the stabbing was executed in a manner that afforded the victim no opportunity to escape or retaliate. It explained the doctrinal requirement for treachery: it exists when the offender employs means, methods, or forms in the execution that directly and especially tend to ensure the execution of the crime without risk to himself arising from any defense the offended party might make.

The Court grounded this conclusion on the testimony that appellant and two others held the victim in place while Jimbo delivered the stabbing thrusts. It also noted that from the five punctured wounds sustained by the victim, three were fatal, involving the left and right lungs and the thoracic cavity. Considering that appellant and co-accused restrained the victim while the stabbing was carried out, the Court found that: first, the means of execution den

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