People v. Bihison
REITERATIONFacts
The Antecedents: Fourteen (14) individuals, including herein accused-appellants Leonardo Bihison, Pepito Kadusale, and Relito Tipontipon, were charged with murder for allegedly conspiring, confederating, and mutually helping one another to kill Honorio Lintag with treachery and evident premeditation using bladed and pointed weapons. Procedural History: Only five of the accused were arrested and brought to trial. The trial court declared the right of the accused to present further evidence waived due to their counsel's repeated failure to appear. The case was archived due to the death of one accused and the escape of another. After the Court of Appeals dismissed a petition for certiorari filed by the appellants regarding their bail, the trial court reinstated the case and proceeded to render judgment. On October 10, 1993, the Regional Trial Court of Cavite, Branch 18, found appellants guilty beyond reasonable doubt of murder and sentenced them to an indeterminate penalty of fourteen (14) years, eight (8) months, and one (1) day of reclusion temporal, as minimum, to seventeen (17) years and four (4) months of reclusion temporal, as maximum, and awarded damages. Appellants Pepito Kadusale, Relito Tipontipon, and Leonardo Bihison appealed to the Court of Appeals. On March 19, 1997, the appellate court affirmed the conviction but increased the penalty to reclusion perpetua, directing the elevation of the records to the Supreme Court. The Petition: Accused-appellants Leonardo Bihison, Pepito Kadusale, and Relito Tipontipon appealed the decision of the Court of Appeals, raising issues regarding the sufficiency of the prosecution's evidence and the trial court's finding of guilt beyond reasonable doubt.
Issue(s)
Whether the evidence presented by the prosecution was sufficient to convict the accused-appellants of murder beyond reasonable doubt, and whether the trial court erred in finding the accused-appellants guilty beyond reasonable doubt of the crime charged. Whether the penalty imposed by the Court of Appeals, reclusion perpetua, is the correct penalty for the crime of murder in the absence of modifying circumstances. Whether the civil liability imposed by the trial court was correctly determined, specifically regarding the award of exemplary damages.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals finding the appellants guilty beyond reasonable doubt of murder and sentencing each of them to suffer the penalty of reclusion perpetua. The award for civil liabilities was modified by deleting the exemplary damages of P25,000.00.
Ratio Decidendi
On the sufficiency of evidence and credibility of witnesses: The Court reiterated the well-established rule that the findings of the trial court on the credibility of witnesses are given the highest degree of respect and are generally not disturbed on appeal, absent strong and cogent reasons to the contrary. The appellants failed to show sufficient justification to warrant a reversal of this rule. The Court found the arguments assailing the credibility of eyewitnesses Rosalinda Mendoza and Irenea Zacarias to be feeble. Eyewitnesses to horrifying events are not expected to recall every detail with perfect accuracy, as different minds react distinctly to sudden and shocking events. The Court found Rosalinda Mendoza's narration of the stabbing and hacking incident to be far from incredulous, and her testimony was corroborated in most respects by Irenea Zacarias. The slight variations in their statements or lack of perfect recollection of minute details do not dilute their credibility or the veracity of their declarations; in fact, inadequacies on minor matters can even enhance the worth of testimony by indicating honesty and unrehearsed responses. The Court found that the mass of testimony jibed on material points, particularly regarding the identity of the culprits and the commission of the crime. On the penalty for murder: The Court affirmed the appellate court's modification of the penalty to reclusion perpetua. It reiterated the basic rule laid down in People vs. Muñoz that Article III, Section 19(1) of the 1987 Constitution, which prohibits the imposition of the death penalty, does not change the periods of the penalty prescribed by Article 248 of the Revised Penal Code, except only insofar as it reduces the death penalty to reclusion perpetua. The range of the medium and minimum penalties remains unchanged. Therefore, in the absence of any generic aggravating or mitigating circumstance that attended the commission of the offense, the applicable sentence for murder is the medium period of the penalty prescribed by Article 248 of the Revised Penal Code, which is reclusion perpetua. On civil liability: The Court modified the civil liability imposed by the trial court by deleting the exemplary damages of P25,000.00, as there was no aggravating circumstance in attendance that would warrant such an award.
Main Doctrine
The appellate court correctly affirmed the conviction for murder and modified the penalty to reclusion perpetua, as the penalty for murder under Article 248 of the Revised Penal Code, as modified by the Constitution, is reclusion perpetua in the absence of modifying circumstances. The credibility of eyewitnesses is generally given great weight and will not be disturbed on appeal absent strong and cogent reasons.