People v. Amaro
REITERATIONFacts
The Antecedents: Ricardo C. Amaro, Armando R. Pante, and Fernando A. Singson were charged with murder for allegedly conspiring, confederating, and mutually helping one another with evident premeditation and treachery, taking advantage of nighttime and superior strength, and with intent to kill, did willfully, unlawfully, and feloniously attack, assault, and stab Augosto Ronda, inflicting mortal wounds that caused his instantaneous death. Procedural History: Armando Pante escaped custody and remained at large. Only Ricardo Amaro and Fernando Singson were arraigned, pleaded not guilty, and stood trial. The Regional Trial Court (RTC) convicted both Amaro and Singson of murder, qualified by abuse of superior strength, sentencing each to suffer the penalty of reclusion perpetua and to pay damages jointly and severally. The Petition: Only Fernando Singson filed an appellant's brief, withdrawing his appeal. He assigned errors concerning his conviction as a principal for murder and the trial court's reliance on conflicting testimonies. The Supreme Court reviewed the evidence on record.
Issue(s)
Whether the trial court erred in finding the accused-appellant Fernando Singson liable as principal for the crime of murder and guilty beyond reasonable doubt for the crime of murder, considering the credibility of prosecution witnesses. Whether the defense of alibi presented by Fernando Singson is sufficient to acquit him. Whether the claim of self-defense by Ricardo Amaro should be considered. Whether the killing was qualified by the aggravating circumstance of abuse of superior strength. Whether the award of damages was proper.
Ruling
The Supreme Court affirmed the judgment of the Regional Trial Court finding accused-appellant Fernando Singson guilty of murder, with the sole modification that the indemnity for death was increased to P50,000.00. The Court found that the guilt of the accused-appellant was proved beyond reasonable doubt.
Ratio Decidendi
On the conviction for murder and the credibility of prosecution witnesses: The Court found that the guilt of the accused-appellant Fernando Singson was proved beyond reasonable doubt. Two prosecution witnesses positively identified the accused as having hacked and stabbed Augosto Ronda. The distance from the scene of the crime and the well-illuminated condition of the scene, due to mercury lamps, the moon, and passing vehicles, enabled the witnesses to observe the commission of the crime and recognize the identity of the accused. The testimonies of the witnesses were straightforward, positive, and consistent, and no proof was adduced to show any evil motive for them to testify falsely. The cross-examination failed to dent their credibility. The eyewitness accounts of the simultaneous hacking and stabbing were consistent with the necropsy report indicating the use of at least two bladed instruments and the infliction of seventeen stab and hack wounds, which demonstrated aggression and intent to kill. On the defense of alibi: The defense of alibi presented by Fernando Singson was found to be inherently weak and could not prevail over the positive identification by the prosecution witnesses. For alibi to be given credence, it must be shown that it was physically impossible for the accused to have been at the scene of the crime. In this case, the house of the alibi witness was only about three kilometers from the scene of the crime, a distance negotiable by motor vehicle in about two minutes. This distance did not establish physical impossibility. Therefore, the defense of alibi was inadequate in light of the unrebutted testimony positively identifying Fernando Singson as one of the perpetrators. On the claim of self-defense by Ricardo Amaro: The Court found Amaro's version of self-defense unconvincing. The necropsy report showing seventeen lesions indicated aggression on the part of the perpetrator, contradicting the claim of unlawful aggression from the victim. Furthermore, the report indicated the use of at least two kinds of bladed instruments (a knife and a bolo), which contradicted Amaro's claim of using only Ronda's bolo. The non-production of the bolo allegedly used by Ronda was also fatal to the defense. The fact that Amaro was found in possession of a knife, one of the instruments used, further weakened his claim. On the qualifying circumstance of abuse of superior strength: The trial court correctly held that the killing was qualified by abuse of superior strength. The accused, armed with knives and bolos, deliberately attacked the lone and unarmed victim. They enjoyed superiority in number and arms, which they utilized in assaulting and slaying Ronda. This constituted a patent inequality of forces and a clear superiority of strength on the part of the aggressors, which they mobilized and took advantage of in the commission of the crime, as held in People v. Verzo. On the award of damages: The trial court correctly awarded damages. However, the indemnity for death was increased from P30,000.00 to P50,000.00 in light of prevailing jurisprudence.
Main Doctrine
The positive identification of the accused by credible prosecution witnesses, corroborated by the physical evidence and the nature of the wounds sustained by the victim, is sufficient to overcome the defense of alibi. Abuse of superior strength is properly appreciated when there is a patent inequality of forces between the victim and the aggressors, and a clear superiority of strength on the part of the aggressors, which they mobilized and took advantage of in the commission of the crime.