Case Summary (G.R. No. 52119)
Factual Background: The Attack, Robbery, and Concealment
The victims, residents of San Felipe, San Nicolas, Pangasinan, carried approximately P40,000.00 and assorted jewelry and gold valued at about P1,740.00. Some of the money was bundled in cloth and tucked at Crisostomo’s waist, while the remaining items were kept in a paper bag placed inside a red bag. The victims were followed by Mateo Padilla, Boy Batin, and Benjamin Padilla.
At the roadside, Mateo Padilla hacked Crisostomo with a bolo. Crisostomo attempted to resist by striking Mateo with a cane, but he later fell to the ground. Mateo continued assaulting Crisostomo, particularly targeting the right side of his neck. Anita, upon witnessing her husband’s attack, fled. Boy Batin blocked her way, struck her hands with his bolo, and then pursued her, hitting her twice at the back until she also fell.
While both victims were prostrate, Benjamin Padilla took from Crisostomo’s waist the piece of cloth containing the money. At that point, Mateo noticed Francisco Doton, who was cutting talahib by the roadside and allegedly witnessed the assault. Mateo ordered Doton to pick up one of the bags containing the Amarillos’ money and to cover with sand the blood scattered at the place. Doton complied. He was then ordered to go home and was warned not to tell anyone, under threat of being killed.
Doton left hurriedly with the red bag. On his way home, he met Wilson Retura and exchanged pleasantries. Before reaching home, Doton found that the red bag contained money. He took the money from the bag, threw the red bag into the river, and thereafter deposited P9,000.00 in his bank account in Urdaneta, Pangasinan. The victims died due to the multiple wounds inflicted by sharp-edged instruments.
The autopsy findings showed severe injuries. Anita Galamgam died from “severe hemorrhage particularly the incised wound at the back, base of the neck with fracture of the spinal column severing the spinal cord and blood vessels.” Crisostomo Amarillo died from “massive hemorrhage due to incised wound base of the neck, right side with fracture of the spinal column severing the spinal cord and big blood vessel of the neck.” Dr. Remedios Santilion, the rural health officer who autopsied the bodies, testified that the wounds were caused by sharp-edged instruments.
Filing of the Information and Trial Dispositions
After police investigation, an information for robbery with double homicide was filed by the Assistant Provincial Fiscal, with the approval of the Provincial Fiscal, in the Court of First Instance of Pangasinan. Boy Batin remained at large, while the other accused were arrested. Upon arraignment, the accused pleaded not guilty.
At the trial’s outset, Francisco Doton was discharged as a government witness upon the prosecution’s motion. After trial on the merits, the trial court rendered a decision on September 25, 1979. The court found Mateo Padilla and Benjamin Padilla, alias “Conang,” guilty beyond reasonable doubt of robbery with double homicide and sentenced each to reclusion perpetua. The court also ordered damages and assessed indemnities for the deaths of the spouses, subject to actual damages and the recovery of P9,000.00. The bolo used by Mateo Padilla was confiscated and forfeited in favor of the government.
The Appeal and the Assigned Errors
Only Benjamin Padilla appealed. He assigned errors, contending that the trial court (1) gravely erred in convicting him on the strength of the testimony of Francisco Doton, a co-accused discharged as a state witness; (2) gravely erred in discrediting his evidence in light of alleged incredibility and gross inconsistencies in Doton’s testimony; and (3) gravely erred in finding him guilty beyond reasonable doubt.
The appeal thus placed the credibility of state witness Doton in issue. Benjamin Padilla also argued that Doton should not have been discharged because, according to the appellant, Doton was allegedly not the least guilty.
The Parties’ Positions on Doton’s Credibility and Motive
The appellant challenged Doton’s discharge and credibility, asserting that Doton should not have been discharged as a state witness for not being the least guilty. The appellant further alleged that Doton was motivated by revenge. The argument was that the appellant was implicated only after his father, Juan Padilla, allegedly informed the police about the loot deposited in the appellant’s bank account in Pangasinan.
The prosecution countered through the lower court’s appreciation: Doton’s participation, while possibly broader than an innocent bystander, did not make him the most culpable. The trial court’s finding, as reflected in the Supreme Court’s recounting, treated Doton as not among those who inflicted the fatal wounds. It characterized his participation as indispensable to the concealment of the fruits, yet held that Doton was still “not the most guilty.” In that setting, the Court treated the discharge as proper and the testimony as admissible and probative.
On the question of timing and motive, the Court noted that in a sworn statement Doton executed on May 17, 1979, he already stated that Benjamin Padilla took the piece of cloth around Crisostomo’s waist. The Court used this point to undermine the claimed revenge motive tied to Juan Padilla’s later bank-deposit revelation. The Court also relied on the record showing that Doton identified Benjamin even before Juan Padilla’s purported disclosure.
The appellant added that Doton’s identification of him was uncorroborated and that he was not mentioned in the sworn statement of Mateo Padilla. The Supreme Court addressed these arguments by emphasizing that a sole testimony, if credible, may suffice for conviction. It further observed that Mateo Padilla might have withheld Benjamin’s identity due to relationship, describing Benjamin as Mateo’s nephew.
Alleged Inconsistencies and the Trial Court’s Appreciation
The appellant pointed to alleged inconsistencies in Doton’s testimony to question reliability. The Court treated such inconsistencies as minor and insufficient to overturn credibility. It explained that apparent contradictions did not necessarily negate Doton’s truthfulness.
In particular, the Court addressed variations in Doton’s statements concerning whether he saw other persons passing the place after the assault. It considered the possibility that Doton’s references could have been to persons other than the accused. The Court also discussed an inconsistency regarding P9,000.00, where Doton had initially described it as part of his wife’s savings before later admitting it was his share in the loot, which he explained by fear for his life.
Additionally, the Court addressed identification details. When Doton was asked whether he knew Mateo and Benjamin, he initially stated that he only knew Mateo; later, he said he knew Benjamin only after the station commander pointed out Benjamin to him. The Court contrasted this with Doton’s sworn statement after he was picked up, where he identified Mateo but could not name the other two, while maintaining that he could recognize them if he saw them again. The Court then related how the station commander brought Doton to the appellant’s residence at Barangay Flores, San Manuel, Pangasinan, and Doton identified Benjamin upon seeing him.
The Appellant’s Defense of Alibi and Its Failure
The Court examined the appellant’s defense, which was alibi. Mateo Padilla testified that he was at home in San Felipe, San Nicolas, Pangasinan at 3:30 P.M. on May 6, 1976. He claimed that in the morning he went to Binalonan to check on his army claims and later stopped at his sister’s house at Flores, San Manuel, Pangasinan.
For his part, Benjamin Padilla claimed that there was a barrio fiesta at Flores, San Manuel, Pangasinan, and that he baptized his son “Banjo” during that occasion. He asserted that he was at home the whole afternoon up to 7:00 P.M., entertaining visitors.
The Supreme Court held that even if the alibi accounts were assumed to be true, the appellant still failed to negate the eyewitness identification. The Court reasoned that it was still possible for the appellant and his companions to have gone to the nearby Barangay San Felipe to commit the offense and then return to their residences.
Legal Basis and Reasoning on
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Case Syllabus (G.R. No. 52119)
Parties and Procedural Posture
- People of the Philippines prosecuted Benjamin Padilla, alias "Conang," for robbery with double homicide.
- The case was originally filed in the Court of First Instance of Pangasinan by the Assistant Provincial Fiscal with the approval of the Provincial Fiscal.
- The information charged Mateo Padilla, Benjamin Padilla, Francisco Doton, and Boy Batin.
- Boy Batin remained at large, while Mateo Padilla and Benjamin Padilla were arrested and tried.
- On arraignment, Mateo Padilla and Benjamin Padilla entered pleas of not guilty.
- At the start of trial, Francisco Doton was discharged as a government witness upon motion of the prosecution.
- The trial court convicted Mateo Padilla and Benjamin Padilla and imposed reclusion perpetua.
- Mateo Padilla commenced serving his sentence and did not appeal, so only Benjamin Padilla appealed.
- The appeal challenged the conviction on grounds related to the discharge and credibility of Francisco Doton, and to the alleged insufficiency of the evidence.
Key Factual Allegations
- The spouses Crisostomo Amarillo and Anita Galamgam, residents of San Felipe, San Nicolas, Pangasinan, were engaged in the buy and sell of gold.
- On May 6, 1976, at about 5:30 in the afternoon, the spouses were on their way home carrying about P40,000.00 and assorted jewelries and gold valued at about P1,740.00.
- The money included items bundled in cloth and tucked at Crisostomo’s waist, and other valuables kept in a paper bag placed inside a red bag.
- The victims were followed by Mateo Padilla, Boy Batin, and Benjamin Padilla.
- Mateo Padilla suddenly hacked Crisostomo with a bolo, after which Crisostomo tried to fend off the attack with a cane but fell to the ground.
- Mateo Padilla continued attacking Crisostomo, particularly on the right side of the neck, until fatal wounds resulted.
- Anita fled upon seeing the attack, but Boy Batin blocked her way and struck her hands with a bolo.
- Boy Batin pursued Anita, struck her twice on the back, and she fell to the ground.
- While Crisostomo and Anita lay prostrate, Benjamin Padilla took from Crisostomo’s waist the cloth containing the money.
- At this juncture, Mateo noticed Francisco Doton, who was cutting talahib by the roadside.
- Mateo instructed Doton to pick up one of the bags containing the Amarillos’ money and to cover the blood with sand.
- Doton complied and was then warned not to tell anyone about what he saw under pain of being killed.
- Doton brought the red bag home, and on the way he met Wilson Retura, with whom he exchanged pleasantries.
- Before reaching home, Doton found the red bag contained money, took the money, threw the empty red bag into the river, and deposited P9,000.00 in his bank account at Urdaneta, Pangasinan.
- The autopsy findings attributed both deaths to severe hemorrhage and incised wounds caused by sharp-edged instruments, with fractures of the spinal column severing the spinal cord and blood vessels.
Issues on Appeal
- The appeal put in issue whether Francisco Doton, a co-accused discharged as a government witness, was properly discharged despite the appellant’s claim that Doton was not the least guilty.
- The appeal challenged the credibility of Doton’s testimony, including alleged inconsistencies and supposed motivations for implicating the appellant.
- The appeal questioned whether the evidence, particularly Doton’s identification, was sufficient to prove Benjamin Padilla’s guilt beyond reasonable doubt.
Defense Contentions
- The appellant argued that Doton should not have been discharged as a state witness because, according to the appellant, Doton was not the least guilty.
- The appellant contended that Doton’s presence during the killing and robbery was unnatural and that Doton should not have calmly witnessed the crime.
- The appellant asserted that Doton’s motivation was revenge because Juan Padilla supposedly informed police authorities about the loot deposited in the appellant’s bank account.
- The appellant argued that Doton identified him only after the alleged bank deposit revelation, and that this timing showed improper motive.
- The appellant maintained that Doton’s identification was not corroborated and that Doton was not mentioned as a participant in the sworn statement of Mateo Padilla.
- The appellant raised alibi, claiming that:
- Mateo Padilla was at home on the day of the crime at about 3:30 P.M.
- Benjamin Padilla was at home attending to a barrio fiesta and entertaining visitors up to about 7:00 P.M.
Prosecution and Witness Treatment
- The prosecution relied on Francisco Doton’s testimony after his discharge as a government witness.
- The Court treated Doton as a witness whose