People v. Abalos

G.R. No. 88189 (July 9, 1996)

Facts:

The case involves Tiburcio Abalos, who was charged with the complex crime of direct assault with murder against Pfc. Sofronio Labine, a member of the Integrated National Police (INP). The incident occurred on March 20, 1983, during the barangay fiesta in Canlapwas, Catbalogan, Samar. The prosecution's key witness, Felipe Basal, testified that he witnessed Abalos attack Labine with a piece of wood, striking him on the head from behind, which resulted in Labine's death due to a severe skull fracture.

The prosecution's narrative indicated that the attack was premeditated, as Abalos had procured the weapon beforehand and struck Labine while he was engaged in his official duties. The information filed against Abalos highlighted the presence of treachery and nocturnity as aggravating circumstances.

Abalos, during his arraignment, pleaded not guilty and presented a defense claiming he acted under a mistaken belief that his father was being attacked by a member of the New People's Army (NPA). He asserted that he did not recognize Labine as a policeman at the time of the incident. After the trial, the Regional Trial Court found Abalos guilty and sentenced him to life imprisonment, along with various damages to be paid to Labine's heirs.

Legal Issues:

1. Whether the trial court erred in giving credence to the prosecution's sole eyewitness while rejecting the defense's version of events.
2. Whether the elements of direct assault with murder were sufficiently established, including the presence of treachery and the status of the victim as a person in authority.
3. The appropriateness of the penalty imposed and the damages awarded to the victim's heirs.

Arguments:

• Prosecution's Arguments:

  • The prosecution relied heavily on the testimony of Felipe Basal, asserting that his account was credible and consistent. They argued that the attack was premeditated and executed with treachery, as Abalos struck Labine from behind while he was engaged in his official duties.
  • The prosecution contended that the absence of corroborating witnesses was not detrimental to their case, as the testimony of a single credible eyewitness is sufficient for conviction.

• Defense's Arguments:

  • Abalos argued that the trial court erred in not believing his version of events, which claimed he acted in defense of his father under a mistaken belief. He contended that the prosecution failed to prove the elements of the crime beyond a reasonable doubt.
  • The defense also pointed out alleged inconsistencies in Basal's testimony and questioned the credibility of the prosecution's evidence, suggesting that the prosecution should have presented additional witnesses to corroborate Basal's account.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding that the prosecution had sufficiently established Abalos's guilt beyond a reasonable doubt. The court emphasized that the testimony of a lone eyewitness, if credible, is adequate for conviction. The court found Basal's account credible, noting that he had a clear view of the incident and was not motivated by any ill will against Abalos.

The court also ruled that Abalos's claim of acting under a mistaken belief was implausible, given that he was aware of Labine's identity as a policeman. The court highlighted that the attack was executed with treachery, as Abalos struck Labine from behind, and that Labine was performing his duties at the time of the assault.

Regarding the penalty, the court modified the trial court's designation of "life imprisonment" to "reclusion perpetua," clarifying that the penalty for the complex crime of direct assault with murder should be imposed in the maximum period. The court also increased the death indemnity to P50,000.00, aligning with current jurisprudential standards.

Significant Legal Principles Established:

1. The testimony of a single credible eyewitness can suffice for conviction, even in the absence of corroborating evidence.
2. The elements of direct assault with murder require proof of the victim's status as a person in authority and the presence of treachery in the commission of the crime.
3. The proper designation of penalties for complex crimes must adhere to the maximum period prescribed by law, and the courts have the discretion to adjust indemnity amounts based on prevailing jurisprudence.