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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Case Overview
- The case involves the appeal of Rene Rosas (accused-appellant) against the decision of the Court of Appeals dated November 29, 2006, which affirmed his conviction for murder by the Regional Trial Court (RTC) of Kabacan, Cotabato.
- The RTC had sentenced Rosas to reclusion perpetua for the murder of Nestor Estacio on September 15, 1995.
Charges and Initial Proceedings
- Accused-appellant was charged with murder in an Information dated October 13, 1998, alleging he shot Estacio with intent to kill, inflicting multiple gunshot wounds that caused instantaneous death.
- Rosas pleaded not guilty during his arraignment on January 5, 1999.
Prosecution's Case
- The prosecution presented several witnesses including:
- Dr. Crisostomo Necessario, Jr. (Municipal Health Officer)
- Wilfredo Bataga (Mayor of Kabacan)
- Antonio Palomar Bataga, Jr. (witness)
- Arceli Estacio (widow of the victim)
- Key details of the incident provided by witnesses:
- On the day of the crime, Antonio Bataga observed Rosas standing near a store and saw Estacio arrive on a motorcycle.
- As Estacio attempted to leave, Rosas shot him from behind at close range and continued firing after Estacio fell.
- Wilfredo Bataga, hearing the gunshots, rushed to the scene and saw Rosas fleeing with a firearm.
- The post-mortem examination revealed that Estacio had multiple gunshot wounds, confirming the cause of death.
Defense's Case
- Rosas