People v. Batidor
REITERATIONFacts
The Antecedents: On January 2, 1995, Donato Asis was shot and killed in his house while taking supper with his wife, Maria Lourdes Asis. The prosecution presented Maria Lourdes Asis and Bienvenido Pagutlan as witnesses. Maria Lourdes Asis testified that she saw the accused, Buenaventura Batidor alias "Tora," shoot her husband through the kitchen railings. Bienvenido Pagutlan testified that he saw the accused and Edgar Conlabong pass by and that the accused made a statement indicating knowledge of the victim's death. The defense presented Buenaventura Batidor, who claimed alibi, stating he was at Sitio Doles, about 7 kilometers away from the victim's residence, at the time of the incident. SPO2 Rolando Santiago, the investigator, testified that Maria Lourdes Asis was hysterical when he first interviewed her on January 3, 1995, and did not identify the killer, but later identified the accused on January 12, 1995. Procedural History: An Information for murder was filed against Buenaventura Batidor alias "Tora." He pleaded not guilty. The Regional Trial Court of Mati, Davao Oriental, found the accused guilty beyond reasonable doubt of murder and sentenced him to suffer the penalty of reclusion perpetua, to indemnify the heirs of the victim, and to pay the costs. The Petition: The accused appealed the decision to the Supreme Court, assigning errors concerning the trial court's appreciation of the credibility of the victim's widow, the sufficiency of the prosecution's evidence, and the disregard of the defense's evidence.
Issue(s)
Whether the trial court erred in giving credence to the testimony of the victim's widow. Whether the trial court erred in convicting the accused despite the alleged uncorroborated testimony of the victim's widow. Whether the trial court erred in disregarding the testimony of the accused and the defense witness; and whether the crime committed was murder.
Ruling
The Supreme Court denied the appeal and affirmed the decision of the trial court. The accused Buenaventura Batidor was found guilty beyond reasonable doubt of murder and sentenced to suffer the penalty of reclusion perpetua. He was ordered to indemnify the heirs of the victim in the amount of P50,000.00.
Ratio Decidendi
On the credibility of the victim's widow: The Court held that the trial court did not err in giving credence to the testimony of Maria Lourdes Asis. While it took her ten days to identify the appellant, her discomfiture and incoherence due to the tragic loss of her husband were understandable reasons for the delay. The Court reiterated that the lapse of time before a witness reveals the assailant's identity does not taint credibility if satisfactorily explained. Her positive identification of the appellant, even through the kitchen railings under the light of a gasera, was found credible. The fact that she was the victim's wife does not automatically impair her credibility; rather, it could make her testimony more credible as she would be seeking justice for her deceased husband. The Court found no reason to doubt her identification, which was resolute even under rigorous cross-examination. On the sufficiency of the prosecution's evidence: The Court affirmed that the prosecution proved the guilt of the appellant with moral certainty. The testimony of Maria Lourdes Asis, a single witness, was deemed positive and credible enough to sustain a conviction for murder. The Court emphasized that the guilt of the accused must rest on the strength of the prosecution's evidence, not on the weakness of the defense. The widow's testimony, being credible and guileless, was sufficient to meet the standard of proof beyond reasonable doubt. On the disregard of the defense's evidence and the crime committed: The Court found the defense of alibi unconvincing. The appellant claimed to be at Sitio Doles, which was only a kilometer away from the crime scene, making physical presence not impossible. The Court reiterated its consistent ruling that alibi is a weak defense, especially when it cannot preclude the accused's presence at the locus criminis. Furthermore, alibi cannot prevail over the positive identification of the appellant by a credible witness who has no motive to testify falsely. The testimony of SPO2 Rolando Santiago, while noting the widow's initial hysteria, did not negate her subsequent positive identification of the appellant. The Court ruled that the crime committed was murder, qualified by treachery. The victim was caught off guard while eating supper and was shot from behind, with no opportunity to defend himself. However, the Court found that evident premeditation was not proven, as there was no clear proof of the time the offender determined to commit the crime, nor acts indicating adherence to that determination with time for reflection. The award of P50,000.00 indemnity ex delicto was affirmed as consistent with jurisprudence.
Main Doctrine
The credible testimony of a single trustworthy witness is sufficient to convict the accused, even on a charge of murder. Alibi cannot prevail over the positive identification of the appellant by a credible witness who has no motive to testify falsely. Treachery qualifies the killing to murder, but evident premeditation was not proven.