People vs. Reduca

G.R. No. 126094-95 (January 21, 1999)

Facts:

On December 4, 1994, at around 10:00 PM, a group consisting of Jose Ebangcara, Ricky Renegado, Felix Temple, and Manolo Cabactulan was walking along Sayre Highway in Barangay Sinanguyan, Don Carlos, Bukidnon, to attend a dance. While walking, they encountered Tito Reduca, who suddenly attacked them with a bladed weapon. Ebangcara was stabbed first, followed by Cabactulan and Renegado. Witnesses testified that Renegado, after being stabbed, identified Reduca as his assailant before succumbing to his injuries shortly thereafter. Cabactulan also sustained injuries but survived after receiving medical attention.

The prosecution presented evidence that Renegado died from multiple stab wounds, while Ebangcara also succumbed to his injuries. The postmortem examinations confirmed that the wounds were inflicted by a knife or bolo. Reduca was charged with two counts of murder for the deaths of Renegado and Ebangcara, and one count of frustrated murder for the attack on Cabactulan.

During the trial, Reduca pleaded not guilty and presented an alibi, claiming he was playing basketball and later sleeping in the barangay hall at the time of the incident. However, the trial court found the testimonies of the prosecution witnesses credible and consistent, leading to Reduca's conviction.

Legal Issues:

1. Whether the trial court erred in giving credence to the prosecution's witnesses despite their alleged intoxication and the circumstances of the attack.
2. The admissibility and weight of Renegado's dying declaration identifying Reduca as his attacker.
3. The validity of Reduca's alibi as a defense against the charges.
4. The characterization of the crimes committed and the appropriate penalties.

Arguments:

Prosecution:

• The prosecution argued that the eyewitnesses, despite being intoxicated, had sufficient opportunity to identify Reduca as the attacker due to the presence of streetlights and their proximity to him during the assault.
• The dying declaration of Renegado was presented as critical evidence, corroborated by other witnesses who heard him identify Reduca as his assailant.
• The prosecution maintained that the circumstances of the attack indicated treachery, as the victims were unarmed and caught off guard.

Defense:

• Reduca's defense contended that the witnesses were too intoxicated to accurately identify him and that the attack occurred in the dark, making identification difficult.
• The defense challenged the credibility of the witnesses, particularly regarding the timing of their statements to the police and inconsistencies in their testimonies.
• Reduca's alibi was presented, asserting that he was playing basketball and could not have been at the scene of the crime.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding no merit in Reduca's appeal. It held that the trial court's assessment of the credibility of witnesses was entitled to great weight, as it had the opportunity to observe their demeanor during testimony. The court found that the prosecution's evidence, including the dying declaration of Renegado, met the legal requirements for admissibility and was credible.

The court ruled that the defense of alibi was weak and insufficient to overcome the positive identification of Reduca by the witnesses. It noted that the distance between the barangay hall and the crime scene was not so great as to make it physically impossible for Reduca to have committed the crime.

Regarding the characterization of the crimes, the court upheld the trial court's finding of treachery in the attacks on Renegado and Ebangcara, leading to their convictions for murder. However, it modified the conviction for the attack on Cabactulan from frustrated murder to attempted murder, as the prosecution failed to prove that the wound inflicted would have caused death without medical intervention.

Significant Legal Principles Established:

1. The credibility of witnesses is primarily assessed by the trial court, and its findings are generally upheld unless shown to be arbitrary.
2. Dying declarations are admissible as evidence if made under a consciousness of impending death and concerning the circumstances of the declarant's death.
3. Alibi is a weak defense that must be supported by strong evidence showing it was physically impossible for the accused to be at the crime scene at the time of the offense.
4. The distinction between attempted and frustrated murder hinges on whether the injuries inflicted were sufficient to cause death.