People v. Obello
REITERATIONFacts
The Antecedents: On September 1, 1991, at around 4:00 p.m., in Quezon City, Danilo de Claro y Infante was allegedly attacked by Rolly Obello y Proquito and Antonio Go. According to the prosecution witness Ricardo de la Cruz, Obello held de Claro by both arms while Go, coming from behind Obello, stabbed de Claro on the abdomen with a fan knife. After the stabbing, both Obello and Go fled. Ricardo de la Cruz attempted to chase them but was stopped by Obello. De Claro was brought to the hospital where he was found to have sustained three stab wounds, which caused his death. Procedural History: An Information for murder was filed against Rolly Obello y Proquito and "John Doe" (later identified as Antonio Go). Antonio Go remained at large, and only Obello was arraigned and tried. The Regional Trial Court of Quezon City, Branch 92, found Rolly Obello y Proquito guilty beyond reasonable doubt of murder and sentenced him to suffer the penalty of reclusion perpetua. The court also ordered him to pay P50,000.00 as civil indemnity and P6,000.00 for funeral expenses. The Petition: Accused-appellant Rolly Obello y Proquito appealed the decision of the trial court, imputing errors in finding him guilty of murder, in giving credence to the testimony of the prosecution witness Ricardo de la Cruz, and in disregarding his own testimony.
Issue(s)
Whether the trial court erred in holding the accused guilty beyond reasonable doubt of the crime of murder, specifically regarding the credibility of witnesses and the accused's testimony. Whether the trial court erred in holding the accused guilty beyond reasonable doubt of the crime of murder, specifically regarding conspiracy and the accused's participation. Whether the trial court erred in holding the accused guilty beyond reasonable doubt of the crime of murder, specifically regarding the crime committed, attendant circumstances, and the award of damages.
Ruling
The appeal is not meritorious. The assailed Decision of the Regional Trial Court is AFFIRMED, but the award of funeral expenses is DELETED.
Ratio Decidendi
On the issue of credibility of witnesses and the accused's testimony: The Court reiterated the principle that the appreciation of and weight accorded to the testimony of witnesses are best left to the sound discretion of the trial judge, whose findings are generally binding on appeal unless there is a clear showing of overlooked facts of substance. The Court found no reason to deviate from this principle in the present case. The testimony of a single witness, if positive and credible, is sufficient to support a conviction. The Court found the testimony of Ricardo de la Cruz to be positive and credible, outweighing the bare denial of the appellant. Minor inconsistencies in the testimony of a witness, such as the exact date of affidavit execution or the exact persons who brought the victim to the hospital, do not necessarily impair credibility, especially when they do not pertain to the core elements of the crime and may even indicate candor. The Court found the appellant's claim of carrying his child while pacifying armed individuals to be against ordinary human instincts. On the issue of conspiracy and appellant's participation: The Court affirmed the trial court's finding of conspiracy, not necessarily through direct evidence of a prior agreement, but through the concerted actions of the appellant and Antonio Go. The Court held that the appellant's act of holding the victim's two arms while Antonio Go stabbed him constituted indispensable cooperation. This act effectively rendered the victim incapable of defending himself, thus fulfilling the requisites of a principal by indispensable cooperation under Article 17, paragraph (3) of the Revised Penal Code. The Court found the appellant's defense of attempting to pacify the assailants while carrying a child to be implausible and against ordinary human instincts. Furthermore, the appellant's flight with the assailant after the incident was considered a strong indicium of guilt. On the issue of the crime committed, the attendant circumstances, and the award of damages: The Court found that the appellant was guilty of murder. The Information alleged murder committed with treachery, taking advantage of superior strength, and evident premeditation. The trial court, in effect, held that the killing was qualified by treachery, noting that the victim was not in a position to defend himself because his hands were held by the appellant while he was being stabbed. The Court agreed that the appellant's participation, by immobilizing the victim, directly contributed to the commission of the crime with treachery, making him liable as a principal by indispensable cooperation. The Court also noted that the appellant's actions, coupled with the stabbing by Go, demonstrated a unity of criminal purpose and design to kill the victim. The Court sustained the award of P50,000.00 as civil indemnity, which is automatically granted in murder cases without need for further proof. However, the award of P6,000.00 for funeral expenses was deleted for lack of competent evidence, such as receipts, to support the claim.
Main Doctrine
The trial court's evaluation of the credibility of a testimony is accorded the highest respect, and such assessment is generally binding on appellate courts, except when the same has been reached arbitrarily or when the trial court has overlooked, misunderstood or misapplied some facts or circumstances of weight and substance. Conspiracy need not be established by direct evidence of a prior agreement; it is sufficient that the accused acted in concert with the same purpose or common design, and were united in its execution. An act of holding the victim's arms while another inflicts the fatal blow constitutes indispensable cooperation, making the co-principal equally guilty.