People v. Donato
REITERATIONFacts
The Antecedents: On March 24, 1980, in Pacac Pequeño, Amulung, Cagayan, Dominador Pascual was called by Dante Donato and Alberto Bautista to a meeting presided over by Andres Balbuena. During the meeting, a dispute arose regarding a lot owned by Perjulio Batarina. Batarina was allegedly mauled by Andres Balbuena, Michael Tong, Alberto Bautista, Segundo Catuiran, Dante Donato, Ben Catuiran, and others. Batarina fell, regained consciousness, ran home, was chased, and his hands were tied. He was then repeatedly boxed and hacked. Subsequently, he was brought near a creek in Tana, Amulung, Cagayan, where he was stabbed multiple times by the group. Ben Catuiran stabbed Batarina with a knife while he was standing, and Dante Donato hacked him. Andres Balbuena ordered Alberto Bautista to get a crowbar and spade, with which Bautista hit Batarina's head. The group then dug a grave to bury Batarina's body, which was found nine days later. Procedural History: The Information charged Alberto Bautista alias Berting, Dante Donato y Catuiran, Segundo Catuiran, Ben Catuiran y Bañares, and Lito Mamanao with murder. Upon arraignment, Dante Donato and Ben Catuiran pleaded not guilty. Segundo Catuiran jumped bail, Alberto Bautista was at large, and Lito Mamanao died during the proceedings, leading to the dismissal of the case against him. The Regional Trial Court found Dante Donato and Ben Catuiran guilty of murder, sentencing them to reclusion perpetua and ordering them to pay indemnity to the heirs of the victim, Perjulio Batarina. The Petition: The accused-appellants, Dante Donato and Ben Catuiran, appealed the decision of the Trial Court, raising several assignments of error, primarily questioning the sufficiency of the prosecution's evidence, the existence of conspiracy, and the rejection of their defenses of denial and alibi.
Issue(s)
Whether the prosecution sufficiently proved the guilt of the accused-appellants beyond reasonable doubt, and whether the defenses of denial and alibi interposed by the accused-appellants are tenable. Whether conspiracy was sufficiently established among the accused-appellants. Whether the crime committed is murder, considering the presence of treachery and evident premeditation. On the penalty and indemnity.
Ruling
The Supreme Court affirmed the decision of the trial court finding the accused-appellants guilty beyond reasonable doubt of the crime of murder, with a modification as to the indemnity to be paid to the heirs of the deceased.
Ratio Decidendi
On the sufficiency of evidence and the defenses of denial and alibi: The Court held that the testimony of a single credible witness, if positive and satisfying the court beyond reasonable doubt, is sufficient for conviction, especially when corroborated. The defense failed to discredit the prosecution witness who identified the appellants as participants in the attack. Dante Donato's claim that the victim was hit by gun butts was contradicted by the autopsy findings, which revealed numerous stab and cut wounds and a fractured skull. The trial court also noted Donato's lack of candor. Ben Catuiran's defense of alibi was deemed fragile and insufficient to overcome the overwhelming evidence. The Court found that the distance between his residence and the crime scene did not render his presence at the meeting physically impossible, making it more likely that he was involved. The trial court correctly disregarded these defenses. On the existence of conspiracy: The Court found that conspiracy existed, as evidenced by the series of acts performed by the assailants in unison. Dominador Pascual testified that both Ben Catuiran and Dante Donato participated in stabbing and hacking the victim. The appellants were with the group that chased, mauled, hacked, and stabbed Batarina. The unity of purpose, preconceived plan, and concerted action in liquidating the victim were evident. The Court reiterated that conspiracy need not be established by direct evidence but can be inferred from the series of acts done in pursuance of a common unlawful purpose, and when proven, all conspirators are liable for the acts of each. On the commission of murder and the presence of treachery and evident premeditation: The Court affirmed the trial court's finding that the crime committed was murder. The evidence showed that Batarina's hands were tied at his back, depriving him of any opportunity to defend himself. While standing, he was stabbed by Ben Catuiran and hacked by Dante Donato, and then repeatedly stabbed by others in the group. This manner of attack, executed without risk to the assailants and with no opportunity for the victim to retaliate, constituted treachery. The Court noted that it was immaterial who inflicted the fatal wound, as all conspirators were liable for the acts of each other. The Court found that evident premeditation could not be appreciated as it was not sufficiently established by the prosecution. This indicates that while the killing was qualified by treachery, the element of planning and deliberation prior to the attack was not proven beyond reasonable doubt. On the penalty and indemnity: The Court affirmed the penalty of reclusion perpetua imposed by the trial court. However, the indemnity to the heirs of the deceased was increased to P50,000.00 in view of prevailing jurisprudence.
Main Doctrine
Conspiracy may be inferred from a series of acts done in pursuance of a common unlawful purpose, and when conspiracy is established, all conspirators are liable for the acts of each, including the aggravating circumstance of treachery, even if they did not directly inflict the fatal wound.