People v. De Gracia
G.R. No. 112984 (November 14, 1996)
Facts:
On February 19, 1992, Crispin Almazan was fatally injured in an attack by the De Gracia brothers—Cresencio, Dalmacio, and Bonifacio—in Cuyapo, Nueva Ecija. The autopsy report revealed multiple stab wounds and a compound fracture of the nasal bone, indicating a violent assault. Following the incident, an Information was filed on April 10, 1992, charging the brothers with murder, alleging that they acted with evident premeditation, treachery, and superior strength.
During the trial, the prosecution presented witnesses, including Anita Almazan and Aries Almazan, who testified about the events leading to Crispin's death. They described how Crispin confronted the De Gracia brothers after they hurled insults at the Almazan family. The confrontation escalated, resulting in Crispin being attacked with various weapons, including a bolo and a spear. The police investigation recovered blood-stained weapons from the crime scene.
Cresencio and Bonifacio De Gracia pleaded not guilty, while Dalmacio remained at large. The trial court ultimately found Cresencio and Bonifacio guilty of murder, sentencing them to reclusion perpetua and ordering them to pay damages to Crispin's heirs.
Legal Issues:
- Whether the trial court erred in convicting the accused based on the prosecution witnesses' testimonies, which the defense claimed were inconsistent and improbable.
- Whether the trial court failed to consider the defense of self-defense and defense of a relative.
- Whether the trial court erred in not applying the mitigating circumstance of voluntary surrender to Bonifacio De Gracia.
Arguments:
For the Accused-Appellants:
- The defense argued that the testimonies of the prosecution witnesses were inconsistent regarding the location of the incident and the weapons used, which undermined their credibility.
- They contended that Crispin Almazan had a motive to provoke the attack and that the accused acted in self-defense, claiming that they were responding to unlawful aggression from Crispin.
- Bonifacio De Gracia sought the benefit of the mitigating circumstance of voluntary surrender, asserting that he had surrendered to the authorities.
For the Prosecution:
- The prosecution maintained that the testimonies, while differing in minor details, were consistent on the essential facts of the case, establishing the guilt of the accused beyond reasonable doubt.
- They argued that the evidence did not support the claim of self-defense, as there was no unlawful aggression from Crispin, who was significantly older and weaker than the accused.
- The prosecution contended that Bonifacio's surrender did not warrant a mitigating circumstance since he did not actively cooperate with the authorities.
Court's Decision and Legal Reasoning:
The court affirmed the trial court's decision, finding no merit in the accused's arguments. It held that the alleged inconsistencies in witness testimonies were minor and did not detract from their overall credibility. The court emphasized that witnesses do not need to provide perfectly consistent accounts, as variations in recollection are natural.
Regarding the self-defense claim, the court found that the accused failed to establish the necessary elements, particularly the presence of unlawful aggression. The court noted that Crispin's age and physical condition made it implausible that he posed a threat to the younger and stronger accused. The severity of the injuries inflicted on Crispin further indicated a deliberate intent to kill rather than a defensive response.
As for Bonifacio's claim of voluntary surrender, the court acknowledged his act of surrender but concluded that it did not mitigate his culpability in the murder. The court modified Bonifacio's sentence to reflect the mitigating circumstance, while Cresencio's sentence of reclusion perpetua was upheld.
Significant Legal Principles Established:
- Witness credibility is assessed based on the overall consistency of their testimonies on material facts, rather than requiring perfect harmony in every detail.
- The burden of proof for self-defense lies with the accused, who must demonstrate the presence of unlawful aggression and the necessity of their response.
- The presence of multiple and severe injuries on a victim can negate claims of self-defense and indicate intent to kill.