People v. Appegu
REITERATIONFacts
The Antecedents: Accused-appellants Ericto Appegu y Materum and brothers Anselmo and Romeo Gamueda y Alcantara were charged with murder for the killing of Rose Binua. The prosecution alleged that on October 4, 1993, in Abulug, Cagayan, the accused, armed with bamboo clubs and a bolo, conspired to kill Rose Binua with treachery, evident premeditation, and abuse of superior strength. The victim sustained multiple wounds, including hack wounds to the head and neck, and a severed hand, which caused her death. The accused denied the charges, presenting an alibi that they were at the house of Barangay Captain Wilfredo Cortez assisting with palay harvesting. Procedural History: The case originated with an Information filed against the accused-appellants for murder. Following their arraignment and plea of not guilty, trial was conducted. The Regional Trial Court (RTC) of Sanchez Mira, Cagayan, Branch 12, found the accused guilty beyond reasonable doubt and sentenced each of them to suffer reclusion perpetua, ordering them to indemnify the heirs of the victim. Aggrieved by this decision, the accused-appellants filed an appeal. The Petition: The accused-appellants appealed to the Supreme Court, raising three main arguments. They contended that the trial court erred in not finding the prosecution's sole eyewitness, Alex Bunnao, incredible due to alleged inconsistencies in his testimony. They also argued that the trial court should have given more credence to their defense of denial and alibi, which they claimed was corroborated by credible witnesses and supported by a weak prosecution case. Finally, they asserted that the trial court erred in not finding them innocent and not guilty beyond reasonable doubt. The appeal questioned the credibility of the eyewitness and the sufficiency of the evidence presented by the prosecution.
Issue(s)
Whether the trial court erred in giving credence to the testimony of the lone eyewitness, Alex Bunnao, despite alleged inconsistencies. Whether the defense of denial and alibi of the accused-appellants should have been given more weight. Whether the killing was qualified by treachery, evident premeditation, and abuse of superior strength.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding the accused-appellants guilty beyond reasonable doubt of murder, with the modification that they are solidarily liable for civil indemnity and moral damages. The penalty of reclusion perpetua for each accused was upheld.
Ratio Decidendi
On the credibility of Alex Bunnao: The Court held that inconsistencies in minor details or collateral matters do not necessarily impair the credibility of a witness, especially when the testimony remains consistent on substantial matters and the positive identification of the accused. The Court found that the alleged inconsistencies in Alex Bunnao's testimony regarding the reason for his presence at the scene (buying cigarettes vs. hunting birds) and the clarity of his view (talahib grass vs. unimpaired view) were either not contradictory or were minor details that did not affect the veracity of his testimony. The Court emphasized that slight contradictions can even strengthen credibility by proving the testimony is not rehearsed. The Court also noted that Alex Bunnao was a minor and unlettered, and that inconsistencies are not unusual, especially for young witnesses. The Court reiterated that as long as the testimonies agree on substantial matters, inconsequential inconsistencies do not dilute credibility. The Court also dismissed the claim of bias due to Alex Bunnao staying with the victim's mother, stating that being a family friend does not automatically make a witness biased, and no improper motive was proven. On the defense of denial and alibi: The Court ruled that for the defense of alibi to prosper, it must be established by positive, clear, and satisfactory proof that it was physically impossible for the accused to have been at the scene of the crime at the time of its commission. The Court found that the distance between Calog Norte (where the accused claimed to be) and Sitio Bannag (the crime scene) was only five kilometers, which is not considered too far to preclude the possibility of their presence. The accused-appellants failed to prove the element of physical impossibility, as it would take only a reasonable amount of time to travel between the two places. Therefore, their alibi was not given credence. On the qualifying circumstances: The Court found that the circumstance of abuse of superior strength attended the commission of the crime. The victim was described as defenseless and attacked by three men, two of whom were armed with deadly weapons. The Court held that an attack by a man with a deadly weapon upon an unarmed and defenseless woman constitutes abuse of superiority. The Court also found that conspiracy existed, as evidenced by the concerted acts of the accused in attacking the victim, demonstrating a unity of purpose and common design. The act of one conspirator was deemed the act of all. While treachery and evident premeditation were alleged, the Court explicitly found abuse of superior strength to be present.
Main Doctrine
Inconsistencies in minor details or collateral matters do not necessarily impair the credibility of a witness, especially when the testimony remains consistent on substantial matters and the positive identification of the accused. The defense of alibi must be proven by positive, clear, and satisfactory proof of physical impossibility to be at the scene of the crime.