Case Summary (G.R. No. 251876)
Factual Background
The initial Information was filed against the accused on June 3, 1988, presenting that they conspired together while armed with deadly weapons to attack the victim, inflicting multiple injuries that resulted in his death. The accused, upon arraignment on June 28, 1988, entered a plea of not guilty. The prosecution's case relied heavily on eyewitness accounts and circumstantial evidence linking the accused to the crime.
Prosecution's Evidence and Witnesses
The prosecution presented Lydia Zilmar, the victim's sister, who testified she witnessed the attack on her brother. She identified the accused as the individuals who chased and attacked her brother, describing their actions in detail. Additional witnesses included Maria Gina Figueroa from the Commission on Audit, who corroborated prior threats made against the victim by the accused, and Pablo Millano, who testified to overhearing the accused planning the victim's murder. The prosecution also submitted Dr. Adoracion L. Cinco's autopsy findings, confirming that the cause of death was a stab wound to the chest.
Defense's Argument
The defense contended that only Virgilio Obzunar was responsible for the victim’s death, claiming self-defense. It presented witnesses who recounted a heated altercation leading up to the stabbing, asserting that Anastacio Macato was the aggressor in the events preceding the incident. Virgilio Obzunar testified that he acted in self-defense, but his version of the events raised inconsistencies and was considered implausible by the trial court.
Trial Court's Ruling
On January 16, 1990, the Regional Trial Court found the accused guilty of murder, sentencing them to reclusion perpetua and requiring them to pay civil indemnity to the victim's heirs. The trial court deemed the eyewitness account credible, emphasizing the prosecution's evidence of conspiracy among the accused, supported by the coordinated nature of their attack.
Appeals and Assignments of Error
In their appeal, the accused raised several issues, questioning the credibility of the prosecution witnesses, the existence of conspiracy, the rejection of self-defense claims, and the sufficiency of the evidence presented. They highlighted concerns over the trial court's evaluation of witness credibility and evidentiary weight.
Court's Analysis on Witness Credibility
The Court maintained that the determination of witness credibility rests primarily with the trial court, which had direct exposure to the testimonies and demeanor of the witnesses. It affirmed the trial court's findings, asserting that there were no significant errors in evaluating the testimonies that would warrant overturning the conviction.
Court's Conclusion on Conspiracy
The Court recognized that conspiracy can be inferred from the behavior of the accused during the commission of the crime, negating the need for direct evidence of an agreement. The testimonies established that all accused actively participated in the victim’s beating and restraint, confirming a collective intent to kill, thereby satisfying the criteria fo
...continue readingCase Syllabus (G.R. No. 251876)
Case Overview
- Court: Supreme Court of the Philippines
- Division: Third Division
- Date of Decision: December 16, 1996
- Case Number: G.R. No. 92153
- Parties: People of the Philippines (Plaintiff-Appellee) vs. Artemio Obzunar, Virgilio Obzunar, Nelson Isanan, Julio Zilmar, Alfredo Isanan, Sr., Alfredo Isanan, Jr., and Jose Superio (Accused-Appellants)
- Nature of the Case: Appeal from a conviction for murder.
Background of the Case
- The accused-appellants were charged with the murder of Anastacio Macato, with the incident occurring on May 6, 1988, in Talalora, Samar.
- An information was filed against the accused-appellants on June 3, 1988, detailing the circumstances of the attack on the victim, which included multiple wounds inflicted with deadly weapons.
- All accused pleaded not guilty during the arraignment on June 28, 1988.
Prosecution's Case
- Eyewitness Testimony: Lydia Zilmar testified that she witnessed the attack on her brother, Anastacio Macato, identifying all seven accused as participants in the assault.
- Motive: Prosecution witnesses established that the victim was guiding a Commission on Audit (COA) team, which may have led to threats from the accused, who were allegedly connected to the local mayor.
- Physical Evidence: Dr. Adoracion L. Cinco conducted a post-mortem examination revealing multiple injuries on the victim, indicating a brutal assault by multiple attackers.
Defense's Case
- The defense contended that only Virgilio Obzunar stabbed the victim in self-defense, arguing that the v