People v. Suguran
REITERATIONFacts
The Antecedents: On June 24, 1984, at around 7:00 or 8:00 PM, Pio Yagma and his family were in their house in Sitio Lokong, Villanueva, Misamis Oriental, engaged in prayer. Suddenly, Alfredo Suguran, Francisco Cabactulan, Jaime Lapingkaw, and another masked man entered the house, tied Cristituto Timaynon, hogtied Pio Yagma and Nenita Yagma, and blindfolded Nenita Yagma. Nenita Yagma heard her husband moan in pain and then silence. Upon untying herself, she found her husband bleeding on the floor. Pio Yagma was brought to the hospital, where he identified Alfredo Suguran and Francisco Cabactulan, along with two others, as his assailants in a written statement signed in the presence of witnesses. Pio Yagma died on June 26, 1984, from massive hemorrhage due to stab wounds. Procedural History: An information for murder was filed against Francisco Cabactulan, Alfredo Suguran, Jaime Lapingkaw, and John Doe. Cabactulan and Lapingkaw jumped bail and their case was archived. Trial proceeded only against Alfredo Suguran. The Regional Trial Court of Misamis Oriental found Alfredo Suguran guilty beyond reasonable doubt of murder, sentencing him to life imprisonment and ordering him to indemnify the heirs of the deceased. The defense presented alibi, claiming Suguran was at the house of Rodulfo Jabeniao and Mrs. Galon from 5:00 PM on January 24, 1984, until the following morning, and that he did not know his co-accused. The Petition: Accused-appellant Alfredo Suguran sought reversal of the trial court's judgment, contending that the court erred in giving credence to Nenita Yagma's testimony, in convicting him of murder due to insufficient evidence of his perpetration, and in convicting him despite the prosecution's failure to prove his guilt beyond reasonable doubt. He argued that Nenita Yagma could not have recognized the assailants due to the dim lighting and her being blindfolded, and that the evidence was insufficient.
Issue(s)
Whether the trial court erred in giving weight and credence to the testimony of Nenita Yagma. Whether the conviction of appellant for murder was proper despite alleged insufficiency of evidence, including the admissibility and weight of the victim's ante mortem statement and the defense of alibi. Whether the prosecution proved appellant's guilt beyond reasonable doubt, specifically regarding the presence of treachery as a qualifying circumstance.
Ruling
The judgment of the trial court is AFFIRMED, with modifications. The penalty imposed is reclusion perpetua, and the indemnity is increased to P50,000.00.
Ratio Decidendi
On the credibility of Nenita Yagma's testimony: The Court found that Nenita Yagma positively identified appellant Alfredo Suguran, whom she knew prior to the incident. The presence of a kerosene lamp provided sufficient illumination for identification, contrary to the appellant's claim. Furthermore, the appellant's face was in full view of the witness and he was in close proximity while tying the victim and the witness. The Court reiterated the principle that findings of fact of the trial court are entitled to great weight and respect on appeal, especially when the trial court is in a better position to observe the demeanor of witnesses. On the sufficiency of evidence and proof of guilt beyond reasonable doubt, including the ante mortem statement and alibi: The Court held that appellant was positively identified by Nenita Yagma. More importantly, the victim, Pio Yagma, positively identified appellant Alfredo Suguran in his ante mortem statement as one of his attackers. This dying declaration was never disputed nor controverted by the appellant. The Court found that the circumstances surrounding the victim's wounds and his subsequent death led to the inescapable conclusion that he was conscious of his impending death, thus satisfying the requisites for a dying declaration. The defense of alibi was deemed weak and could not prevail over the positive identification and the dying declaration. On the qualifying circumstance of treachery: The Court affirmed the trial court's appreciation of treachery. The sudden entry of the assailants into the house, the hogtying of the victims, and the fact that they were caught by surprise and unable to defend themselves, especially when the victim was hogtied and defenseless before being stabbed, demonstrated that the mode of execution deliberately insured the consummation of the crime without risk to the assailants. This mode of attack tended directly and especially to insure the commission of the offense without any peril to the offenders arising from the defense which the offended party might have made.
Main Doctrine
An ante mortem statement, if meeting the requisites of a dying declaration, is admissible as evidence. Alibi cannot prevail over positive identification and a dying declaration. The penalty for murder under Article 248 of the Revised Penal Code is reclusion perpetua, not life imprisonment.