Title
People vs. Donato
Case
G.R. No. 94530
Decision Date
Mar 6, 1992
Perjulio Batarina was killed in 1980 by a group, including Dante Donato and Ben Catuiran, who tied, hacked, and stabbed him before burying his body. The Supreme Court upheld their murder conviction, citing credible witnesses, conspiracy, and treachery, rejecting their alibi and denial defenses.

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:

  1. The trial court erred in favoring the prosecution's narrative over their defense.
  2. There was insufficient evidence to prove guilt beyond a reasonable doubt.
  3. The existence of conspiracy was improperly concluded.
  4. 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

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.