People v. Batulan
REITERATIONFacts
The Antecedents: On June 21, 2003, at around 7:30 in the evening, Ruben Pacho, a jeepney driver, was with his wife, Letecia, when their jeepney stopped to pick up passengers. Alvin Pagapulaan, a barker, demanded payment for his services, which led to an altercation with Ruben's conductor. Ruben intervened by giving Pagapulaan ₱5.00, but Pagapulaan, displeased, cursed Ruben and hit the jeepney, causing passengers to alight. Ruben then took a samurai from under his seat. As Ruben alighted, he was surrounded and attacked by Jose Batulan (appellant), Alvin Pagapulaan, Renato Fuentes, and Junjun Fuentes. Pagapulaan used the samurai to slice Ruben's face and nose, Junjun stabbed him with a knife, Renato struck his nape with a stone, and Batulan hacked him with a samurai. Letecia testified that all four accused took turns attacking Ruben. Ruben sustained serious injuries and died at the hospital. SPO4 Elmo Ausejo testified that his team responded to a stabbing incident and apprehended Batulan running away from the crime scene, recovering a bloodied Batangas knife from him. Letecia confirmed Batulan was one of the assailants. PO2 Joel Salo arrested Pagapulaan, who was identified by Letecia as one of the attackers. Procedural History: Appellant Jose Batulan, along with Alvin Pagapulaan, Renato Fuentes, and Junjun Fuentes, were charged with murder. Pagapulaan, being a minor, was released and later pleaded guilty to homicide. The trial proceeded against Batulan, Renato, and Junjun. The prosecution presented Letecia Pacho, SPO4 Ausejo, PO2 Salo, and Everly Waban Batalla. The defense presented Batulan, Renato, and Junjun. The Regional Trial Court (RTC) found Batulan, Renato, and Junjun guilty of murder, sentencing them to reclusion perpetua and ordering them to pay civil indemnity, moral damages, and actual damages. Only Batulan appealed to the Court of Appeals (CA). The CA affirmed the conviction, finding that while treachery was not present, the killing was qualified by abuse of superior strength. The CA ruled that Batulan's guilt was sufficiently proven by the testimonies of SPO4 Ausejo and his co-accused Renato and Junjun, and the recovery of the bloodied Batangas knife from him. The Petition: Appellant Batulan sought his acquittal, arguing that the CA erred in affirming his conviction despite Letecia's failure to identify him in court and averring that the testimonies of his co-accused implicating him were inadmissible under the principle of res inter alios acta. The Office of the Solicitor General (OSG) defended the CA's decision, asserting that Batulan's guilt was sufficiently established by other witnesses and the physical evidence, and that the concerted acts of the accused proved conspiracy.
Issue(s)
Whether the Court of Appeals erred in affirming appellant's conviction for murder, specifically regarding the sufficiency of evidence for identification. Whether the testimonies of co-accused implicating appellant are admissible. Whether conspiracy was established among the accused. Whether the killing was qualified by treachery or abuse of superior strength. Whether the penalty and damages awarded were proper.
Ruling
The appeal is DENIED. The Decision of the Court of Appeals is AFFIRMED with MODIFICATION. Appellant Jose Batulan y Macajilos is found GUILTY of MURDER and sentenced to suffer the penalty of reclusion perpetua. He is ordered to pay the heirs of Ruben Pacho civil indemnity, moral damages, and exemplary damages of ₱75,000.00 each, and temperate damages of ₱50,000.00. These amounts shall earn six percent (6%) interest per annum from finality of the decision until fully paid.
Ratio Decidendi
On the sufficiency of evidence for appellant's identification: The Court held that appellant's guilt was sufficiently established by credible and competent evidence, notwithstanding the victim's widow's failure to identify him in open court. The testimonies of his co-accused, Renato and Junjun Fuentes, positively identified appellant as one of the assailants who stabbed the victim in the neck with a Batangas knife. Furthermore, SPO4 Ausejo positively identified appellant as the person he arrested fleeing the crime scene and found in possession of a blood-stained Batangas knife, which was later identified in court as one of the weapons used. The circumstances, including the bystander's report, the chase, the arrest, and the recovery of the bloodied knife, formed an unbroken chain leading to the reasonable conclusion of appellant's guilt. The Court reiterated that positive identification by credible witnesses, coupled with circumstantial evidence, can be sufficient for conviction. On the admissibility of co-accused testimonies: The Court ruled that the principle of res inter alios acta does not apply to testimonies given in open court where the accused had the opportunity to cross-examine the witnesses. The statements of Renato and Junjun Fuentes identifying appellant were made in open court during direct examination and they did not waver when cross-examined. Therefore, their testimonies were admissible and properly considered by the courts below. The Court emphasized that the rule against res inter alios acta pertains to extrajudicial declarations, not to sworn testimonies subject to adversarial scrutiny. On the existence of conspiracy: The Court affirmed the finding of conspiracy among appellant and his co-accused. Evidence showed that all four accused knew each other, were present at the time of the killing, surrounded the victim when he alighted his jeepney, took turns attacking him with various weapons, and immediately escaped thereafter. These coordinated actions, motivated by a single criminal impulse to kill Ruben, established a common purpose. The Court reiterated that once conspiracy is established, each conspirator is criminally liable for the acts of the others, regardless of who delivered the fatal blow, as the act of one is the act of all. On the qualifying circumstance: The Court agreed with the CA that treachery did not attend the killing, as there was no showing that the appellant deliberately chose a method of attack to ensure the accomplishment of the crime without risk of retaliation. However, the Court found that abuse of superior strength qualified the killing to murder. This was evident from the notorious inequality of forces between the victim and the four accused, who ganged up on Ruben, used multiple weapons (samurai, knife, stone), and overwhelmed him with their synchronized assault. The Court clarified that abuse of superior strength does not require the victim to be completely defenseless but considers the excessive force used by the aggressors relative to the victim's means of defense. On the penalty and damages: The Court upheld the sentence of reclusion perpetua for murder. Following recent jurisprudence, the awards for civil indemnity and moral damages were increased to ₱75,000.00 each. Exemplary damages of ₱75,000.00 were also awarded. The actual damages of ₱21,000.00 were deleted due to lack of competent proof, and in lieu thereof, temperate damages of ₱50,000.00 were awarded. All monetary awards were ordered to earn six percent (6%) interest per annum from finality of the decision until fully paid.
Main Doctrine
The positive identification of an accused by credible witnesses, even if the victim's eyewitness failed to identify the accused in court, coupled with circumstantial evidence such as possession of the murder weapon shortly after the crime, is sufficient to establish guilt beyond reasonable doubt. Conspiracy among the accused, evidenced by their coordinated actions and common criminal purpose, makes each conspirator liable for the acts of the others. Abuse of superior strength, characterized by a notorious inequality of forces between the victim and the aggressors, qualifies the killing to murder.