Labong v. People
REITERATIONFacts
The Antecedents: On the night of January 31, 1993, in Davao City, a commotion occurred at a basketball court. According to a prosecution witness, Antonieto Labong, along with his brothers Ferdinand and Aplonieto, confronted Raul Batulan. Labong allegedly held Batulan by the neck with a handgun, while his brothers pushed him towards an abandoned outpost. The witness reported that Labong and Ferdinand struck Batulan's head with handguns, and Aplonieto stabbed him multiple times in the stomach. Despite his injuries, Batulan managed to fire a gun. The victim was later pronounced dead on arrival at the hospital, with the necropsy report indicating severe hemorrhage secondary to multiple stab wounds as the cause of death. Procedural History: Antonieto Labong was arrested and pleaded not guilty. His brothers, Ferdinand and Aplonieto, remain at large. The Regional Trial Court of Davao City, Branch 10, found Labong guilty beyond reasonable doubt of homicide and sentenced him to an indeterminate penalty, with additional civil liabilities. Labong appealed this decision to the Court of Appeals. On April 27, 1998, the Court of Appeals affirmed the trial court's decision in its entirety, with the sole modification of deleting the award for burial expenses. This led to the present appeal. The Petition: The petitioner, Antonieto Labong, filed a petition for review on certiorari under Rule 45 of the Revised Rules of Court, raising three main issues. He argued that the Court of Appeals erred in ruling that he conspired with his brothers in the killing of Raul Batulan. He also contended that the appellate court erred in holding that the testimony of a single eyewitness was sufficient for his conviction and that it wrongly disregarded his and his witness's testimonies. The petitioner sought to overturn the decision of the Court of Appeals.
Issue(s)
Whether the Court of Appeals erred in ruling that petitioner conspired with his two brothers in the killing of Raul Batulan. Whether the Court of Appeals erred in ruling that a single eyewitness of the prosecution sufficed to convict the petitioner. Whether the Court of Appeals erred in disregarding the testimony of petitioner and his witness.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals in its entirety, upholding the conviction of the petitioner for homicide. The Court found that the evidence supported the conviction, particularly the clear and unshaken testimony of an eyewitness who positively identified the petitioner. The Court also found that conspiracy could be inferred from the collective actions of the petitioner and his co-accused, indicating a common purpose. The petitioner's self-serving testimony was deemed insufficient to overcome the eyewitness's positive identification.
Ratio Decidendi
On the issue of conspiracy: The Court held that while there was no direct evidence of a prior agreement to commit the crime, conspiracy could be inferred from the acts of the accused. The eyewitness account described the petitioner holding the victim by the neck, his brothers pounding the victim's head, and one brother stabbing the victim. These concerted actions demonstrated a joint purpose and complicity among the accused, thus establishing conspiracy. The Court emphasized that the chain of circumstances evinced complicity among the accused, even though only the petitioner was arrested and brought to trial. On the sufficiency of a single eyewitness: The Court ruled that the testimony of a single eyewitness, if clear, credible, and positive, is sufficient to convict an accused beyond reasonable doubt. The eyewitness, Judy Rom, directly and categorically identified the petitioner as one of those who assaulted the victim. The Court found his testimony to be clear and unshaken, and any perceived inconsistencies were on minor and irrelevant details that did not affect his credibility. This testimony, corroborated by the physical evidence from the necropsy report, was deemed sufficient for conviction. On the disregard of the petitioner's and his witness's testimony: The Court found the petitioner's testimony to be self-serving and diametrically opposed to the prosecution's evidence. It held that such testimony could not prevail over the positive identification made by the eyewitness. Similarly, the testimony of the defense witness, Maria Luisa Suico, which corroborated the petitioner's version, was also implicitly disregarded in favor of the prosecution's credible evidence. The Court reiterated that the eyewitness's account was direct and categorical, and the physical evidence supported it.
Main Doctrine
The testimony of a single eyewitness, if clear, credible, and unshaken, is sufficient to convict an accused beyond reasonable doubt. Conspiracy may be inferred from the joint acts of the accused indicative of a common purpose and concerted action.