Case Digest: PEOPLE OF THE PHILIPPINES v . MARCELO ALETA et al. 584 SCRA 578 (2009)

PEOPLE OF THE PHILIPPINES v . MARCELO ALETA et al. 584 SCRA 578 (2009)

A witness’ testimony deserves full faith and credit where there exists no evidence to show any dubious reason or improper motive against the accused, or why he should implicate the accused in a serious offense. While the deceased Acob‘s mother Marina was at the community center of Barangay Nagsurot, Burgos, Ilocos Norte, she heard a commotion at the yard of Marcelo Aleta, et al. (the Aletas). Soon after returning home, she told Acob that there was a quarrel at the Aletas‘ compound. Against his mother‘s pleas, Acob repaired to the Aletas‘ compound. Marina followed and upon reaching appellants‘ compound, she saw her nephew appellant Rogelio striking her son Acob twice at the left cheek and at the back of his head with a piece of wood, causing Acob to fall on the ground. She thereafter saw Rogelio striking Acob‘s father-in-law Duldulao twice on the face drawing his eyes to pop up, and again on the head causing him to fall on the ground. Rogelio then ran towards the family house whereupon Marina heard gunshots. Rogelio‘s brothers-co-appellants Jovito, Marlo and Ferdinand and their father Marcelo at once began clubbing Acob and Duldulao with pieces of wood, mainly on the face and head, as well as on different parts of their bodies. Even while the victims were already lying prostrate on the ground, Marcelo, Jovito, Marlo, and Ferdinand continued to hit them. And when Rogelio emerged from the house, he got another piece of wood and again clubbed the victims. As found by Dr. Arturo G. Llabore, a medico-legal officer of the National Bureau of Investigation-Regional Office, San Fernando, La Union who supervised the exhumation and autopsy of the bodies of Acob and Duldulao on June 3, 1994, the two victims suffered multiple abrasions, lacerations, open wounds, contusions and fractures on their face, head, scalp, arms, legs and thighs; that Acob‘s death was due to ―hemorrhage, intercranial, severe, secondary to traumatic injuries, head‖ while Duldulao‘s was due to ―hemorrhage, intercranial, severe, secondary to traumatic injuries, head, multiple;‖ that both victims could have died within one (1) hour after the infliction of the injuries; and that because of the severity and multiplicity of the injuries sustained, the same could not have been inflicted by only one person. Ferdinand and Marlo interposed self-defense and defense of relative, respectively. Additionally, Marlo invoked voluntary surrender as a mitigating circumstance. Marcelo, Rogelio and Jovito invoked alibi. Crediting the prosecution version, the trial court found the Aletas guilty beyond reasonable doubt of Murder in both cases. The trial court held that although what triggered the incidents was never explained, Acob and Duldulao died as a result of the attacks on them, qualified by abuse of superior strength and cruelty. The Aletas moved for a reconsideration of the trial court‘s decision which was denied. Hence, the present appeal.

ISSUE:

Whether or not the trial and the appellate courts erred in giving full weight and credence to the testimonies of the prosecution witnesses

HELD:

As in most criminal cases, the present appeal hinges primarily on the issue of credibility of witness and of testimony. As held in a number of cases, the trial court is best equipped to make the assessment on said issue and, therefore, its factual findings are generally not disturbed on appeal, unless: (1) the testimony is found to be clearly arbitrary or unfounded; (2) some substantial fact or circumstance that could materially affect the disposition of the case was overlooked, misunderstood, or misinterpreted; or (3) the trial judge gravely abused his or her discretion. As held in a catena of cases and correctly applied by both lower courts, Marina‘s positive identification of the Aletas as the assailants and her accounts of what transpired during the incidents, which were corroborated on all material points by prosecution witnesses Loreta Duldulao (Loreta) and Willie Duldulao (Willie), as well as the findings of the medico-legal officer, carry greater weight than the Aletas‘ claims of self-defense, defense of relative and alibi. More particularly, that Marina‘s narration was so detailed all the more acquires greater weight and credibility against all defenses, especially because it jibed with the autopsy findings. Respecting the defense‘s questioning of Loreta‘s testimony that Willie had told her that Duldulao was already dead, but was later to claim that on reaching the scene of the crime, Duldulao was still alive, lying on the ground and being clubbed by Aleta, et al., the same deserves scant consideration. Far from being inconsistent, the same is in sync with the other witnesses‘ claim and Marlo‘s own admission that Aleta, et al. continued to club the two victims even as they lay motionless and helpless on the ground. At any rate, inconsistencies in the testimonies of witnesses which refer to minor and insignificant details, such as whether Duldulao was still alive or not, cannot destroy Loreta‘s testimony. Minor inconsistencies in fact even guarantee truthfulness and candor. A witness‘ testimony deserves full faith and credit where there exists no evidence to show any dubious reason or improper motive why he should testify falsely against the accused, or why he should implicate the accused in a serious offense. That the prosecution witnesses are all related by blood to the Aletas should a fortiori be credited, absent a showing that they had motive to falsely accuse the Aletas.