People v. Trigo
REITERATIONFacts
The Antecedents: Bertito Trigo was charged with parricide for the death of his wife, Alicia Dequiña Trigo. The information alleged that on May 30, 1983, the accused, with evident premeditation, stabbed his estranged wife, inflicting wounds that caused her death. Procedural History: The Regional Trial Court, Branch 16, Roxas City, convicted Bertito Trigo of parricide on September 16, 1985, appreciating the mitigating circumstance of voluntary surrender and sentencing him to reclusion perpetua. The court also ordered him to indemnify the heirs of the deceased. The Petition: Bertito Trigo appealed the decision, arguing that the trial court erred in relying heavily on the testimony of prosecution witness Marcos Fuentes and disregarding the defense's evidence, and in finding him guilty beyond reasonable doubt.
Issue(s)
Whether the trial court erred in relying on the testimony of the prosecution witness Marcos Fuentes and in finding the accused-appellant guilty beyond reasonable doubt of parricide. Whether the relevance of motive was properly considered given the eyewitness account. Whether the mitigating circumstance of voluntary surrender was correctly appreciated.
Ruling
The Supreme Court affirmed the conviction of Bertito Trigo for parricide, with a modification increasing the indemnity to P30,000.00. The Court found the appeal to be without merit.
Ratio Decidendi
On the credibility of Marcos Fuentes and the finding of guilt: The Supreme Court reiterated the rule that the findings of the trial court on the credibility of witnesses are given great weight and respect by appellate courts, as the trial court is in a better position to observe their deportment. The testimony of Marcos Fuentes, who positively identified Bertito Trigo stabbing his wife, was found to be clear and positive, with no showing of ulterior motive. The Court held that the testimony of a single credible witness is sufficient for conviction. Furthermore, the Court found the defense's claim that Orline Buaco was the assailant improbable, citing several circumstances: the improbability of the first attack aimed at the wife if intended for the accused, the greater improbability of multiple stab wounds on the wife if the assailant intended to stab the accused, the wife's failure to shield herself or retaliate, the accused's failure to stay with his wounded wife after Buaco fled, and the accused's failure to return to check on his wife's medical attention after securing police protection. These circumstances, coupled with the eyewitness account, sufficiently proved the guilt of the accused-appellant beyond reasonable doubt. On the relevance of motive: The Supreme Court stated that motive is only relevant when the identity of the perpetrator is in dispute, there are no eyewitnesses, or suspicion might fall on multiple individuals. In this case, the identity of the accused was positively established by an eyewitness, rendering the issue of motive irrelevant. On the appreciation of voluntary surrender: The Supreme Court disagreed with the trial court's appreciation of voluntary surrender as a mitigating circumstance. The Court reasoned that the accused went to the police station to report that his wife was stabbed by Buaco and to seek protection due to fear for his own safety, not to surrender for the killing of his wife. Therefore, his action did not constitute voluntary surrender in the legal sense. Despite this disagreement, the penalty of reclusion perpetua was deemed correctly imposed.
Main Doctrine
The credibility of eyewitness testimony, when clear and positive and without ulterior motive, is sufficient for conviction, and motive is irrelevant when the identity of the accused is positively established. The circumstances surrounding the incident must be considered to belie defenses that contradict eyewitness accounts.