People v. Bantillo
REITERATIONFacts
The Antecedents: On March 6, 1990, Francisco Temblor was shot and killed in Barangay Batuanan, Carles, Iloilo. The victim was accompanied by his son, Ruel Temblor, who was about 30 meters ahead. Ruel heard gunfire, looked back, and saw his father fall. He then saw six persons, armed with unlicensed firearms (pugakhang), surround his father. Ruel testified that he saw Alex Bantillo shoot his father on the head. The assailants then fled. Another eyewitness, Alfredo Bandojo, corroborated Ruel's account, stating he saw the six accused emerge from bushes and coconut trees, heard explosions, and saw Alex Bantillo shoot the victim on the head. Procedural History: Assistant Provincial Prosecutor Arsenio Villa charged Alex Bantillo, Ernesto Asuncion, Larry Asuncion, Rodolfo Atanas, Paquito Fernandez, and Anoring Badando with murder. Upon arraignment, Alex Bantillo and Ernesto Asuncion pleaded not guilty. The Regional Trial Court of Iloilo City, Branch 25, found Bantillo and Asuncion guilty of murder, with treachery as a qualifying circumstance and superiority of force and band as aggravating circumstances, sentencing them to reclusion perpetua. The court also ordered them to indemnify the victim's family. The Petition: Alex Bantillo and Ernesto Asuncion appealed the RTC decision, arguing that the trial court erred in giving full credence to the testimonies of the prosecution witnesses, in giving credence to Ruel Temblor's testimony regarding motive, in not giving weight to the defense of alibi, and in not acquitting them.
Issue(s)
Whether the trial court erred in giving full credence to the testimonies of prosecution witnesses Ruel Temblor and Alfredo Bandojo. Whether the trial court erred in giving credence to Ruel Temblor's testimony regarding the motive for the killing. Whether the trial court erred in not giving weight to the defense of alibi presented by the accused. Whether treachery attended the killing.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding Alex Bantillo and Ernesto Asuncion guilty of murder. They were sentenced to reclusion perpetua and ordered to pay civil damages to the heirs of the victim.
Ratio Decidendi
On the credibility of prosecution witnesses: The Court held that the assessment of the credibility of witnesses is primarily the domain of the trial court, which has the opportunity to observe their demeanor. The testimonies of Ruel Temblor and Alfredo Bandojo were found to be positive, credible, and corroborated each other. Both witnesses knew the appellants personally and had unobstructed views of the incident. Their testimonies were not impeached, and they had no ill motive to falsely implicate the appellants. The Court rejected the defense's attempt to discredit Ruel by suggesting he should have been killed too, deeming it speculative. The Court also found Bandojo's testimony alone sufficient for conviction. On the motive for the killing: The Court reiterated that motive is not an element of the crime and does not have to be proven. Even if the motive ascribed (victim's support for another candidate in the barangay election) was considered flimsy, it did not preclude conviction. The Court noted that people can be killed for no apparent reason. Therefore, the trial court did not err in giving credence to Ruel's testimony regarding the motive. On the defense of alibi: The Court found the alibi of the appellants unconvincing. For an alibi to prosper, it must not only show that the accused were elsewhere but also that they were so far away that they could not have been present at the crime scene. The appellants claimed to be in Manlot, which was accessible by pumpboat to Batuanan within one to one and a half hours. This proximity rendered their alibi weak, especially in light of the positive identification by prosecution witnesses. The Court emphasized that alibi crumbles in the face of positive identification. On the presence of treachery: The Court agreed with the trial court that treachery attended the killing. The appellants lay in ambush behind coconut trees and bushes and suddenly attacked the unsuspecting victim with gunfire. This sudden and unexpected attack, executed with deliberate intent, was deemed treacherous. The number and location of wounds, some with powder burns indicating close range firing, further supported the finding of treachery. The Court clarified that treachery absorbs the aggravating circumstances of band and superiority of force, and thus, these should not have been considered separately.
Main Doctrine
The positive identification of the appellants by prosecution witnesses, who had no ill motive to falsely implicate them and whose testimonies were corroborated, prevails over the defense of alibi. Treachery attended the killing, absorbing the aggravating circumstances of band and superiority of force.