People vs. Fabrigas

G.R. No. 115005 (September 5, 1996)

Facts:

The case involves the murder of Ernesto Bron, who was killed on January 1, 1992, in Sitio Little Caramay, Barangay Magara, Roxas, Palawan. The accused, brothers Catalino Fabrigas, Jr. and Rafael Fabrigas, were charged with murder under Article 248 of the Revised Penal Code, with the prosecution alleging evident premeditation and treachery as aggravating circumstances.

The background of the case reveals a land dispute between Ernesto Bron and Reynaldo Fabrigas, the brother of the accused. Following the death of Ernesto's brother, Ernesto took over the disputed land and sought resolution through local authorities. On the night of the incident, Ernesto and his wife, Belinda, were awakened by calls from the accused, who claimed they wanted to settle the land dispute. When Ernesto went outside, he was attacked; Catalino, Jr. held Ernesto's hands while Rafael stabbed him multiple times with a bolo.

Witnesses, including Belinda and a neighbor, Leopoldo de la Cruz, testified to the events. Belinda, who was present during the attack, identified the accused as the perpetrators. Despite efforts to get Ernesto to the hospital, he succumbed to his injuries shortly after the attack.

The police investigation revealed a bolo handle with bloodstains at the scene, but no autopsy was performed until days later due to the absence of a doctor. The autopsy confirmed the cause of death as cardiac tamponade and hypovolemic shock due to stab wounds.

The defense presented an alibi, claiming that the accused were at home during the time of the murder, supported by testimonies from their family and a helper. However, the trial court found the alibi unconvincing and ruled against the accused.

Legal Issues:

1. Whether the trial court erred in giving credence to the testimonies of the prosecution witnesses, particularly Belinda Bron.
2. Whether the prosecution proved the guilt of the accused beyond a reasonable doubt.
3. Whether the circumstances of treachery and evident premeditation were present in the commission of the crime.
4. The appropriateness of the damages awarded to the victim's heirs.

Arguments:

Prosecution:

• The prosecution argued that the testimonies of Belinda and Leopoldo were credible and consistent, establishing the identity of the assailants and the circumstances of the crime.
• They contended that the attack was premeditated and executed with treachery, as the accused lured Ernesto under the pretense of reconciliation.
• The prosecution maintained that the absence of the murder weapon did not negate the evidence of the crime, as the testimonies were sufficient to establish guilt.

Defense:

• The defense claimed that the testimonies of the prosecution witnesses were inconsistent and biased, particularly pointing out alleged improbabilities in Belinda's account of the events.
• They argued that the alibi presented was credible, asserting that it was physically impossible for the accused to have committed the crime given the distance from their residence.
• The defense also questioned the credibility of the prosecution's evidence, including the lack of the murder weapon and the motive for the crime.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding the accused guilty of murder. The court held that the testimonies of Belinda and Leopoldo were credible and corroborated each other, despite minor inconsistencies. The court emphasized that discrepancies in minor details do not necessarily undermine a witness's credibility.

The court found that treachery was present, as the accused used a ruse to gain the victim's trust before attacking him. The court ruled that the attack was executed in a manner that ensured the victim could not defend himself, thus qualifying the killing as murder.

The court also noted that while evident premeditation was not proven, the presence of treachery sufficed to uphold the conviction. The defense of alibi was dismissed due to the positive identification of the accused by the witnesses.

Regarding damages, the court reduced the amounts awarded to the victim's heirs, stating that claims for actual damages must be supported by evidence, such as receipts, which were lacking in this case.

Significant Legal Principles Established:

• The credibility of witnesses is not diminished by minor inconsistencies in their testimonies, especially when they provide a coherent account of the events.
• Treachery can be established through the use of deceit to facilitate an attack, rendering the victim defenseless.
• The absence of the murder weapon does not preclude a conviction if there is sufficient testimonial evidence to establish the crime and the identity of the perpetrators.