People v. Marollano
REITERATIONFacts
The Antecedents: On May 14, 1989, Domingo Guadamor was allegedly stabbed by Dionisio Marollano alias "Jun," Consorcio Molleno, and "John Doe" with bladed instruments, with treachery and evident premeditation, resulting in his death. The incident occurred in Barangay Sta. Fe, Pilar, Sorsogon. Procedural History: An Information for murder was filed. After trial, the Regional Trial Court of Sorsogon, Branch 52, convicted Dionisio Marollano of murder, sentencing him to reclusion perpetua and ordering him to indemnify the heirs. Consorcio Molleno was acquitted, and "John Doe" remained at large. The case against "John Doe" was provisionally dismissed. The Petition: Dionisio Marollano appealed his conviction, arguing that the prosecution's evidence was insufficient to prove his guilt beyond reasonable doubt and that the witnesses' testimonies were unreliable due to contradictions.
Issue(s)
Whether the trial court gravely erred in convicting the accused-appellant despite the alleged absence of evidence proving his guilt beyond reasonable doubt, and whether the testimonies of prosecution witnesses Cesar Mapa and Belleza Favia Guadamor were credible despite alleged contradictions. Whether the victim's ante-mortem statement is admissible as a dying declaration or part of the res gestae. Whether the defense of alibi and denial can prevail over positive identification and dying declarations. Whether treachery attended the commission of the crime. Whether the awarded civil indemnity is proper. Whether the awarded actual damages and loss of earning capacity are proper.
Ruling
The appeal is denied. The assailed Decision of the trial court is affirmed with modifications regarding the award of damages. The accused-appellant Dionisio Marollano is found guilty beyond reasonable doubt of murder.
Ratio Decidendi
On the alleged absence of evidence and credibility of witnesses: The Court reiterated the settled jurisprudence that the trial court's assessment of witness credibility is entitled to great weight and is conclusive on appeal, absent arbitrariness. While the defense pointed to alleged contradictions in the testimonies of Cesar Mapa and Belleza Favia Guadamor, the Court found that inconsistencies in minor matters do not impair credibility. Specifically, alleged contradictions in Cesar Mapa's testimony regarding the sequence of events were deemed more apparent than real and were sufficiently explained. The Court noted that the victim's outcry did not preclude Mapa from witnessing the stabbing. Regarding Belleza Favia Guadamor's testimony, the Court found significant contradictions concerning the location where she learned of the stabbing and the identity of the assailants, which weakened her credibility. However, the Court found Cesar Mapa's testimony, along with the victim's ante-mortem statements, to be sufficient for conviction. On the admissibility of the victim's ante-mortem statement: The Court held that the victim's statements identifying Dionisio Marollano as his assailant were admissible both as a dying declaration and as part of the res gestae. The victim's stab wound on the right side of his stomach, causing significant blood loss, indubitably generated a consciousness of impending death. His statements were made under this realization and concerned the cause and circumstances of his death. The victim was competent to testify, and his declarations were made before he had time to contrive or devise, concerning the startling occurrence of being stabbed. The Court emphasized that such declarations are entitled to the highest credence. On the defense of alibi and denial: The Court found the defense of alibi and denial to be weak and unavailing against positive identification and dying declarations. The appellant's alibi of being at a drinking spree fifty meters away from the crime scene was rejected because it did not establish the physical impossibility of his presence. Furthermore, his claim of helping the victim was uncorroborated and self-serving. The Court stressed that alibi requires proof of physical impossibility of presence at the crime scene, which was not established here. The close proximity of the alleged alibi location to the crime scene also undermined the defense. On treachery: The Court affirmed the trial court's finding that treachery attended the killing. Witness Cesar Mapa testified that the appellant stabbed the victim from behind while the victim was relieving himself. This manner of attack ensured the commission of the crime without risk to the assailant from any defense the victim might have mounted, thus qualifying the crime as murder. On civil indemnity: The Court sustained the award of civil indemnity of P50,000.00. On damages: Regarding actual damages, the Court reduced the award to P5,000.00, based on the only receipt presented and admitted by the defense. The award for loss of earning capacity was modified and reduced to P280,000.00, applying the formula for life expectancy and deducting living expenses from the gross income to arrive at net earning capacity. Additionally, the Court awarded moral damages of P20,000.00 to the widow, finding that she suffered mental anguish and bereavement due to the victim's death.
Main Doctrine
Inconsistencies and contradictions in minor matters do not impair credibility. Alibi and denial do not prevail over a victim's dying declaration or statement as part of the res gestae, which points to the accused as the assailant. The trial court's assessment of witness credibility is given great weight.