Case Summary (G.R. No. 94530)
Key Individuals and Context
- Petitioners/Accused-Appellants: Dante Donato and Ben Catuiran
- Victim: Perjulio Batarina
- Co-accused (at large): Alberto Bautista, Segundo Catuiran
- Additional parties: Andres Balbuena, Dominador Pascual (key witness)
- Location: Pacac Pequeno, Amulung, Cagayan
Facts of the Case
The Information filed in the trial court charged the accused with murder under Article 248 of the Revised Penal Code, claiming that on March 24, 1980, Donato, Catuiran, and several others, armed and in conspiracy, attacked, assaulted, and ultimately killed Batarina. The prosecution’s evidence indicated a planned meeting to confront Batarina regarding a land dispute, which escalated into violence leading to his death.
Prosecution's Evidence
Witness Dominador Pascual testified that during a meeting, Batarina was assaulted and subsequently chased by the group led by Andres Balbuena. After being subdued, Batarina was tied up and repeatedly stabbed and hacked by the accused and others. Medical evidence, including an autopsy report, corroborated this account, detailing multiple stab wounds and confirming that Batarina's hands were tied, thus preventing him from defending himself.
Defense Appeals
The appellants challenged the conviction on several grounds, primarily asserting that:
- The trial court erred in favoring the prosecution's narrative over their defense.
- There was insufficient evidence to prove guilt beyond a reasonable doubt.
- The existence of conspiracy was improperly concluded.
- Their defenses of denial and alibi were incorrectly dismissed.
Analysis of Evidence
The court held that credible witness testimony is sufficient for conviction, even if it comes from a single individual, provided it is corroborated by other evidence. The trial court found the testimonies credible, rejecting Donato's claim that he did not participate in the killing, especially as it contradicted clinical findings from the autopsy, which indicated the nature and type of injuries sustained by Batarina. Furthermore, the court noted that neither appellant effectively established a physical impossibility that would substantiate their alibi claims.
Conspiracy and Treachery
The trial court concluded that sufficient evidence existed to establish conspiracy among the accused. The simultaneous and coordinated actions of the assailants indicated a premeditated agreement to harm the victim. While elements of treachery were ackno
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Case Overview
- This case concerns an appeal from the decision of a Trial Court that found the accused-appellants, Dante Donato and Ben Catuiran, guilty of the crime of murder.
- The appellants were sentenced to reclusion perpetua, ordered to pay indemnity of P30,000 to the heirs of the victim, Perjulio Batarina, and to pay the costs proportionately.
Background of the Case
- The Information for murder was filed against several individuals, including the appellants, for the events that transpired on March 24, 1980, in Amulung, Cagayan.
- The charge alleged that the accused conspired to kill Batarina, inflicting multiple injuries that led to his death.
Procedural History
- Upon arraignment, Donato and Catuiran pleaded not guilty, while other co-accused had varying status such as jumping bail or being deceased.
- The prosecution presented witness testimonies and autopsy results to substantiate the claims against the accused.
Evidence Presented by the Prosecution
- Witness Dominador Pascual testified that he was summoned by Donato and Bautista to a meeting where Batarina was assaulted.
- During the meeting, Batarina was publicly accused and subsequently mauled by multiple individuals.
- After being tied up, Batarina was severely attacked, leading to h