People v. Coscos
REITERATIONFacts
The Antecedents: The Information charged Alfredo Coscos and John Doe (later identified as Roel Marcujos) with Murder for allegedly conspiring, confederating, and mutually helping each other to attack and shoot Johnny de la Cruz with treachery and evident premeditation, using a firearm, which caused his death. John Doe remained at large. Belly de la Cruz, the victim's widow, testified that on October 31, 1995, she heard stones being thrown at their dogs and saw Alfredo Coscos, his son Ricky, and Roel Marcujos entering their premises. Coscos, holding a kerosene lamp, called out to her husband, and an altercation ensued regarding Coscos' son being bitten by their dog. Belly then heard a burst of gunfire, saw her husband staggering, heard two more shots, and saw her husband fall, observing Coscos holding a gun. Fearing for her life, she remained silent until the assailants left. Her husband was brought to the hospital but was pronounced dead on arrival. Belly testified on the victim's monthly earnings and income from farm animals and a quarry business, as well as funeral expenses. Dr. Ricardo Rodaje, who conducted the autopsy, testified that the cause of death was gunshot wounds, with the victim sustaining three wounds on the neck and head. He recovered a slug from the neck but could not determine the bullet type, stating the victim was likely standing or sitting when shot in the neck with the gun at a lower angle, and the head wound suggested the victim was already lying down. The wounds indicated a short firearm was used, and he could not determine the order of the wounds, noting powder burns would not be traceable if the assailant wore gloves. Procedural History: The trial court found Alfredo Coscos guilty beyond reasonable doubt of Murder and sentenced him to suffer the penalty of reclusion perpetua, ordering him to pay damages. The accused appealed. The Petition: The accused-appellant faulted the trial court for giving full faith and credence to the sole eyewitness account of Mrs. Belly de la Cruz, for failing to establish his guilt beyond reasonable doubt, and for convicting him of Murder despite the prosecution failing to prove the aggravating circumstance of treachery.
Issue(s)
Whether the trial court erred in giving full faith and credence to the sole eyewitness account of Mrs. Belly de la Cruz. Whether the prosecution failed to establish the guilt of the accused beyond reasonable doubt. Whether the trial court erred in convicting the accused of Murder as the aggravating circumstance of treachery was not duly proved.
Ruling
The Supreme Court affirmed the decision of the trial court, finding accused-appellant Alfredo Coscos guilty beyond reasonable doubt of the crime of Murder.
Ratio Decidendi
On the issue of the sole eyewitness account: The Court held that the lone declaration of a sole eyewitness is sufficient to convict if found credible, as credibility is weighed, not numbered. The trial judge's evaluation of witness testimony is accorded great respect. The accused-appellant failed to demonstrate that the trial court misinterpreted or misapprehended the evidence. Belly de la Cruz positively identified the accused-appellant as the assailant, and her testimony was found credible despite the defense's attempt to discredit it through other witnesses and the introduction of a letter claiming responsibility by the NPA. On the issue of guilt beyond reasonable doubt: The Court found that the prosecution established the guilt of the accused beyond reasonable doubt. The positive identification by the widow, Belly de la Cruz, was crucial. The defense's denial was considered inherently weak and unsubstantiated by strong evidence of non-culpability. The defense's theory that the NPA was responsible, supported by a letter, was deemed unreliable and potentially a concoction to create doubt, especially since copies were sent to both the judge and the defense counsel. On the issue of treachery: The Court agreed with the trial court that the crime was attended by treachery. Treachery is characterized by the deliberate and unexpectedness of the attack, giving the victim no chance to resist or escape. Although there was a prior altercation, the Court found no evidence that it was heated or that the accused-appellant was provoked. The victim was not facing the accused-appellant when shot, and the attack was sudden and unexpected. The fact that the accused-appellant tested negative for powder burns was not conclusive proof of his innocence, as this test is not definitive.
Main Doctrine
The positive identification of the accused by a sole eyewitness is sufficient for conviction if found credible. Denial by the accused, being inherently weak, cannot prevail against such positive identification. A negative result in a paraffin test is not conclusive proof that the accused did not fire a gun. Treachery is present when the attack is sudden and unexpected, giving the victim no opportunity to defend himself, even if there was a prior altercation.