Title
People vs. Rosas
Case
G.R. No. 177825
Decision Date
Oct 24, 2008
Rene Rosas convicted of murder for shooting Nestor Estacio from behind; alibi rejected, treachery proven, sentenced to reclusion perpetua.

Case Summary (G.R. No. 135087)

Charges and Trial Proceedings

The original charge of murder against Rosas was filed via an Information dated October 13, 1998, alleging that he attacked and shot Estacio with treachery. Upon his arraignment on January 5, 1999, Rosas pleaded not guilty. The Regional Trial Court (RTC) of Kabacan heard the testimonies of the prosecution witnesses, including local officials and the victim's widow, while the defense primarily relied on Rosas' alibi and denial.

Prosecution's Version of Events

According to the prosecution, on the morning of September 15, 1995, several witnesses, including Antonio Palomar Bataga, Jr. and Wilfredo Bataga, observed Rosas shooting Estacio at close range. Following the initial shot, additional gunfire was heard as Rosas attempted to ensure Estacio's death. After the incident, eyewitnesses testified that they pursued Rosas but lost him in the crowd. The autopsy confirmed multiple gunshot wounds that caused the victim's immediate death.

Defense's Position

Rene Rosas presented an alibi, stating he was in a boarding house in Kabacan during the time of the shooting. His girlfriend corroborated part of his story, stating they were at a restaurant when the alleged murder occurred. Rosas argued that the prosecution failed to conclusively identify him as the shooter, asserting that the witnesses provided inconsistent accounts.

Trial Court's Findings

On February 1, 2001, the RTC found Rosas guilty of murder, citing the qualifying circumstance of treachery due to the nature of the attack. The court sentenced him to reclusion perpetua and ordered him to pay various damages to Estacio's heirs. The decision was based on the weight of witness testimonies and the evidence presented, which the court deemed credible.

Appeal and Court of Appeals Decision

Rosas appealed his conviction to the Court of Appeals, which upheld the RTC's ruling on November 29, 2006. The appellate court affirmed Rosas' guilt and modified the damages awarded, reducing actual damages but increasing temperate damages.

Supreme Court Review

Upon further appeal to the Supreme Court, the primary arguments from Rosas concerned the alleged insufficiency of evidence to prove murder and the lack of specificity in the indictment regarding the qualifying circumstance of treachery. The Supreme Court carefully reviewed the witness testimonies and evidence, ultimately deeming the identification of Rosas as the shooter credible, despite minor inconsistencies in witness accounts.

Final Rulings on Evidence and Alibi

The Supreme Court reaffirmed the trial court's acceptance of witness credibility, emphasizing that discrepancies in minor details do not detract from the solid identification of Rosas as the perpetrator. Furthermore, the defense of alibi was dismissed due to the short distance from the crime scene to Rosas' alleged location, coupled with the fact that his alibi did not prove physical impossibility.

Judgment on the Qualifying Circumstance

Rosas' appeal against the sufficiency of the Information regarding treachery was also rejected. The Court clarified that while specific language is not mand

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