Case Summary (G.R. No. 188710)
Facts
On the day of the incident, a group of farmers including Francisco Arobo, Jr., Calim, and others were working on a farm. At approximately 8:00 a.m., Arobo heard gunfire and witnessed appellant and Midtimbang shooting at Calim, who was positioned near his plow. Arobo observed both assailants firing rifles from an oblique position behind the victim before fleeing the scene. The post-mortem examination confirmed that Calim suffered multiple gunshot wounds to various parts of his body.
The defense asserted mistaken identity, claiming that the appellant was wrongly identified as his co-accused due to their physical resemblance. Appellant's testimony indicated he was at home with his wife at the time of the shooting, and another witness testified he saw the Midtimbang brothers commit the crime, exonerating appellant. However, this witness later admitted that he was not at the scene of the crime but rather five kilometers away, which cast doubt on his credibility.
Ruling of the RTC
The Regional Trial Court (RTC) of Kabacan, Cotabato, found appellant guilty of murder and sentenced him to reclusion perpetua, requiring him to pay civil indemnity to Calim's heirs. The RTC dismissed the defense of mistaken identity as appellant had knowledge of the resemblance between him and Midtimbang. The court emphasized the presence of evident premeditation and treachery in the crime, establishing that the attack was sudden and left the victim without any opportunity for defense.
Ruling of the Court of Appeals
On appeal, the Court of Appeals (CA) upheld the conviction but modified the ruling regarding damages, ordering the appellant to pay moral damages in addition to civil indemnity. The CA highlighted the strong identification of the appellant by prosecution witnesses, dismissing the defense's claims of mistaken identity. However, the CA found that the prosecution failed to prove evident premeditation, reversing the RTC’s finding on that aspect.
Issue
The primary legal question was whether the appellant was rightly convicted of murder. The appellant's arguments centered around the purported lack of evidence proving his guilt beyond a reasonable doubt and the inadequacies in establishing treachery and premeditation in the crime.
Our Ruling
The Supreme Court found that, while the prosecution sufficiently established that the appellant was involved in the killing of Calim, it failed to prove the presence of treachery. The Court ruled that treachery must be clearly
...continue readingCase Syllabus (G.R. No. 188710)
Court and Case Information
- Jurisdiction: Supreme Court of the Philippines
- Case Number: G.R. No. 188710
- Date of Decision: June 02, 2014
- Division: First Division
Parties Involved
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellant: Matimanay Watamama a.k.a. Akmad Salipada
- Co-Accused: Teng Midtimbang (at large)
Background of the Case
- This case arises from an appeal against the decision of the Court of Appeals dated January 30, 2009, which modified the Regional Trial Court's ruling from June 9, 2005.
- The RTC found the accused guilty beyond reasonable doubt of murder for the death of Abubakar Calim.
Facts of the Case
- On October 26, 1998, around 8 AM, Francisco Arobo, Jr. and five other farmers, including the victim Calim, were working on a farm.
- Arobo noticed gunfire and observed the accused and his co-accused firing at Calim, who was slumped near his plow.
- The attackers were positioned behind Calim and fired multiple shots, prompting witnesses to seek cover.
- Following the attack, a report was made to a barangay kagawad.
- A postmortem examination confirmed that Calim had sustained multiple gunshot wounds.
Defense Argument
- The accused claimed he was mistaken for his co-accused due to their physical resemblance and asserted that he was at home at the time of the incident.
- His wife testified that she saw the co-accused after the gunshots and alleged they claimed to have shot Calim for stealing a carabao.
- A defense witness,