Case Summary (G.R. No. 135693)

Conviction and Sentencing of Accused-Appellants

The trial court convicted the accused-appellants, Cornelio Gelin and Manuel Gelin, of murder for the shooting and hacking to death of Dionisio Gelin. They were sentenced to reclusion perpetua. The accused-appellants appealed the conviction, arguing that the trial court erred in accepting the prosecution's eyewitness testimonies despite alleged inconsistencies and in disregarding their alibi defense.

• Accused-appellants were convicted of murder.
• Sentenced to reclusion perpetua.
• They appealed the conviction.
• Claimed trial court erred in accepting eyewitness testimonies.
• Argued inconsistencies in testimonies and alibi defense were overlooked.

Credibility of Prosecution Witnesses

The Supreme Court affirmed the trial court's decision, finding the prosecution's eyewitness testimonies credible and sufficient for conviction. The inconsistencies pointed out by the accused-appellants were deemed minor and did not undermine the core of the witnesses' accounts, which clearly identified the accused-appellants at the crime scene and their active participation in the murder.

• Supreme Court affirmed trial court's decision.
• Eyewitness testimonies were credible and sufficient.
• Inconsistencies were minor and did not undermine testimonies.
• Witnesses clearly identified accused-appellants at the crime scene.

Weight of Evidence and Testimony

The Court emphasized that the weight and sufficiency of evidence are determined by the credibility and quality of testimony rather than the number of witnesses. The absence of additional witnesses to corroborate the testimonies of Ida Balagbis and Joel Gelin was not detrimental to the prosecution's case, as the testimonies presented were deemed credible and sufficient for conviction.

• Evidence weight determined by credibility and quality of testimony.
• Absence of additional witnesses not detrimental to prosecution.
• Testimonies of Ida Balagbis and Joel Gelin were credible and sufficient.

Minor Lapses in Testimony

The Court noted that minor lapses in the testimonies of witnesses do not necessarily affect their credibility. For instance, approximations regarding distances or the timing of events do not invalidate the core of their testimonies. Such minor errors can even enhance the credibility of the witnesses by suggesting that their accounts were not rehearsed.

• Minor lapses in testimony do not affect credibility.
• Approximations regarding distances or timing are not invalidating.
• Minor errors can enhance credibility by indicating uncoached testimonies.

Findings of the Trial Court

The factual findings of the trial court were given great weight, as the appellate court found no compelling reason to disturb them. The trial court's assessment clearly established the culpability of the accused-appellants, and the appellate court upheld this assessment.

• Trial court's factual findings given great weight.
• No compelling reason to disturb trial court's findings.
• Culpability of accused-appellants clearly established.

Conspiracy and Common Purpose

The actions of both accused-appellants indicated a conspiracy, as they acted with a common purpose and concerted action to kill the victim. The method of attack was premeditated and ensured that the victim, who was unarmed, had no opportunity to defend himself.

• Actions indicated a conspiracy between accused-appellants.
• Common purpose and concerted action to kill the victim.
• Attack was premeditated and left the victim defenseless.

Defenses of Denial and Alibi

The defenses of denial and alibi presented by the accused-appellants were found to be weak and insufficient to counter the positive identification by witnesses. The Court noted that the accused-appellants failed to provide clear and convincing evidence of physical impossibility to support their alibi.

• Defenses of denial and alibi deemed weak.
• Positive identification by witnesses prevailed.
• Accused-appellants failed to prove physical impossibility for alibi.

Aggravating Circumstances

The trial court correctly disregarded the alleged aggravating circumstances of evident premeditation, abuse of superior strength, and abuse of authority, as the prosecution did not provide sufficient evidence to support their presence in this case.

• Trial court disregarded alleged aggravating circumstances.
• Insufficient evidence from prosecution to support these claims.

Treachery as a Qualifying Circumstance

The Court upheld the trial court's finding that treachery attended the killing, qualifying the crime as murder. The attack was characterized by its deliberate an...continue reading