People v. Dayaday
REITERATIONFacts
The Antecedents: Accused-appellant Roque Dayaday y Dagooc was charged with Murder for allegedly attacking and killing Basilio Gallenero on October 27, 2005, around 10:00 PM in Norala, South Cotabato. The Information alleged that the killing was attended by treachery and evident premeditation, and aggravated by illegal possession of firearms. Procedural History: The Regional Trial Court (RTC) of Surallah, South Cotabato, Branch 26, convicted Roque of Murder, sentencing him to reclusion perpetua and ordering him to pay damages. The Court of Appeals (CA) affirmed the RTC's decision. Roque appealed to the Supreme Court. The Petition: Roque questioned the CA's affirmation of his conviction, primarily challenging the credibility of the eyewitness, Alex Gallenero (son of the victim), and alleging inconsistencies in his testimony. He also questioned the CA's finding of treachery.
Issue(s)
Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of murder based on eyewitness testimony. Whether the eyewitness testimony of Alex Gallenero was credible despite his relationship with the victim and alleged inconsistencies. Whether treachery was sufficiently proven to qualify the killing to murder.
Ruling
The Supreme Court dismissed the appeal for lack of merit, affirming the conviction of Roque Dayaday y Dagooc for Murder. The Court modified the monetary awards for civil indemnity, moral damages, and exemplary damages, increasing each to P75,000.00, and ordered that all monetary awards shall earn interest at the legal rate of six percent (6%) per annum from the date of finality of the Decision until fully paid.
Ratio Decidendi
On Issue 1: The Court affirmed the conviction for murder, holding that the eyewitness testimony of Alex Gallenero was credible and sufficient to establish the guilt of the accused-appellant beyond reasonable doubt. The Court reiterated the rule that findings of the trial court, especially when affirmed by the appellate court, are accorded high respect and will not be overturned unless there is a showing of overlooked facts or circumstances of weight and substance. On Issue 2: The Court found the eyewitness testimony of Alex Gallenero to be credible. The imputation of bias due to his relationship with the victim was dismissed, as relationship does not automatically impair credibility and may even enhance it if there is no showing of improper motive. The alleged discrepancies between Alex's affidavit and his testimony regarding the number of witnesses were deemed immaterial and did not detract from his positive identification of the assailant. The Court noted that such minor inconsistencies can even strengthen credibility by showing the testimony was not rehearsed. On Issue 3: The Court sustained the CA's finding that treachery attended the killing. Treachery exists when the attack is sudden, unexpected, and without warning, giving the victim no opportunity to defend himself. The evidence showed that the victim was shot from behind while walking, rendering him defenseless. The fact that a stab wound was also inflicted did not negate treachery, as the victim was already vulnerable due to the gunshot wounds. The Court found treachery to be evident, qualifying the crime to murder.
Main Doctrine
The positive identification of the accused by the eyewitness, coupled with the presence of treachery, is sufficient to sustain a conviction for murder, even in the face of a defense of alibi. Discrepancies in the number of wounds or minor inconsistencies between affidavits and testimonies do not necessarily impair credibility and may even strengthen it by negating rehearsal.