People v. Sabado
REITERATIONFacts
The Antecedents: On December 1, 1983, at about 5:00 PM, appellant Juanito Sabado participated in harvesting palay. Later that evening, around 10:00 PM, while appellant and the victim, Emiliano Natura, were in a tent lighted by a kerosene lamp, two witnesses, Pedro Delfin and Ceferino Natura, left the tent to get cigarettes. Shortly after leaving, they heard a shot, turned back, and saw appellant standing over the victim, who was lying down, and firing a gun at him successively. Appellant then fled the tent. The victim was found dead with multiple gunshot wounds. The victim's father incurred P8,560.00 in funeral expenses. Procedural History: The Regional Trial Court (RTC) found appellant Juanito Sabado guilty of Murder, sentencing him to reclusion perpetua, to indemnify the offended party, and to pay actual, moral, and exemplary damages. The Petition: Appellant appealed the RTC decision, assailing the trial court's credence to prosecution witnesses' testimonies and disregard of his version of the incident, seeking acquittal.
Issue(s)
Whether the trial court erred in giving credence to the testimonies of prosecution witnesses Pedro Delfin and Ceferino Natura. Whether the trial court erred in not giving credence to the accused's testimony implicating Patrolmen Ruben Pituc and Romeo Imus. Whether the trial court erred in not acquitting the accused based on reasonable doubt.
Ruling
The Supreme Court affirmed the judgment of conviction but modified the penalty. The Court ruled that the appellant was guilty of Murder qualified by treachery. The penalty was modified to an indeterminate sentence of ten (10) years and one (1) day of prision mayor, as minimum, to eighteen (18) years, eight (8) months and one (1) day of reclusion temporal, as maximum.
Ratio Decidendi
On the issue of credibility of prosecution witnesses: The Court held that appellate courts generally do not disturb the factual findings of the trial court, which is in a better position to assess witness credibility. Appellant was positively identified by Pedro Delfin and Ceferino Natura, who were only five meters away from the tent, which was lit by a kerosene lamp. The relationship of the witnesses to the victim (compadre and brother) does not automatically render their testimony less credible, especially in the absence of proof of improper motive. The Court noted that appellant himself testified there was no bad blood between him and the witnesses. The positive identification by prosecution witnesses was given greater weight than the appellant's denial. On the issue of the accused's testimony implicating police officers: The Court found appellant's defense that police officers shot the victim to be incredible. Appellant claimed he was afraid to report the incident immediately because the perpetrators were policemen. However, he admitted to visiting the Municipal Hall, where the police force is headquartered, a week after the killing, and seeing the two patrolmen he accused. The Court found it highly improbable that he would go to the police headquarters if he genuinely feared the officers he claimed were murderers. Furthermore, he never reported the incident to the authorities despite the victim being his brother-in-law. On the issue of reasonable doubt: The Court found no reasonable doubt to warrant acquittal. The positive identification by prosecution witnesses, coupled with the implausibility of the appellant's defense, led the Court to affirm the conviction. The defense's reliance on the examining physician's statement about the size of exit wounds was dismissed, as the physician considered it a mere possibility and concluded that one firearm was likely used, with variations in exit wounds being normal due to bullet trajectory. The Court also dismissed the notion that the victim's alleged troublemaking nature justified the killing.
Main Doctrine
The positive identification of the accused by prosecution witnesses, supported by clear and straightforward testimony, outweighs the accused's negative assertion and explanation, especially when the accused's own testimony raises doubts regarding his credibility. Treachery is present when the victim is attacked while lying down, rendering him unable to offer defense.