G.R. No. 145993 - People vs. Mallari

Case Summary (G.R. No. 145993)

Legal Proceedings

An information for murder was filed against Rufino on December 12, 1996, which alleged that he fatally injured Joseph Galang deliberately using his Isuzu truck. Rufino pleaded not guilty during his arraignment. The trial included testimonies from various witnesses, including members of the victim's family and medical experts, as well as Rufino's own defense.

Prosecution’s Testimony

Witness Liza Galang testified about earlier confrontations between Joseph and Rufino, detailing an event where Joseph admonished Rufino and his brothers for speeding near their home, which escalated into a physical chase. Other witnesses corroborated Liza's account, indicating that after Joseph fled from an attempted stabbing by Rufino and his brothers, Rufino pursued him in the truck, ultimately hitting and killing him. Dr. Erwin Escal confirmed the cause of death as injuries consistent with being struck by a vehicle.

Defense Argument

Rufino and his wife, Myrna, provided a narrative that framed the incident as an accident. Rufino claimed he was driving carefully at a moderate speed when Joseph threw stones at his vehicle, causing him to lose control. They contended that his actions lacked malicious intent, suggesting that the circumstances surrounding the incident were misconstrued.

Trial Court's Findings

The trial court ruled that Rufino acted with criminal intent, noting the premeditated nature of his actions, evidenced by the series of confrontations preceding the incident. It also affirmed that the use of a motor vehicle considerably qualified the crime as murder, which is punishable by either reclusion perpetua or death under the Revised Penal Code.

Assessment of Witness Credibility

The decision emphasized the importance of witness credibility, affirming the trial court’s determination as it had observed the witnesses' demeanor firsthand. There was a pronounced distinction in the credibility of the testimonies; prosecution witnesses demonstrated consistency, while the defense's account lacked coherence.

Deliberation on Culpability and Sentence

The appellate court upheld the trial court’s assessment, concluding that the evidence clearly demonstrated Rufino's intent to kill Joseph by using his vehicle. The court rejected Rufino's argument that the use of the truck was incidental, noting that it was crucial in the actual execution of the crime.

Mitigating Circumstances

Rufino argued for the application of voluntary surrender as a mitigating circumstance. The appellate court agreed that, although he surrendered after the incident, the serious nature of his crime overshadowed this claim. Based on the absence of aggravating circumstances and the presence of voluntary surrender, the penalty was reduced from death to reclus