People vs. Verano

G.R. No. 110109 (November 21, 1996)

Crispolo Verano was convicted of murdering Jason Bagcal; the appellate court upheld the verdict.

Facts:

On October 14, 1991, eight-year-old Jason Bagcal was murdered in a cemetery in Tandag, Surigao del Sur. Accused of the crime were Crispolo Verano, Edgar Siman, and Benjamin Martinez. The information charged them with murder, alleging that they conspired to kill Jason with treachery and evident premeditation, inflicting multiple wounds that resulted in his death. The prosecution presented evidence that on the day of the incident, Verano was seen driving a "trisikad" (a bicycle with a sidecar) with Jason as a passenger. Witnesses, Roberto Cagampang and Fedelio Quezada, observed the accused entering the cemetery with Jason, noting that Siman and Martinez were armed.

Later that evening, Verano was seen pledging a gold-plated Seiko wristwatch, which belonged to Jason, to a waitress named Yolanda Pineda. The following day, Verano returned to sell the watch to Pineda. The victim's father, Fortunato Bagcal, learned of the watch's sale and reported it to the police, leading to Verano's arrest. During police questioning, Verano confessed to killing Jason, stating that he was coerced by Siman, who threatened him with a firearm. He admitted to striking Jason with a wooden cross and taking the wristwatch from him.

The post-mortem examination revealed that Jason died from cerebral hemorrhage due to massive brain damage, with an estimated time of death around 48 hours before the examination. The two co-accused, Siman and Martinez, denied involvement, claiming they were elsewhere during the incident.

Legal Issues:

  1. Whether the circumstantial evidence presented by the prosecution was sufficient to establish the guilt of Crispolo Verano beyond a reasonable doubt.
  2. Whether the trial court erred in convicting Verano while acquitting his co-accused, Siman and Martinez.

Arguments:

  • Prosecution's Argument: The prosecution argued that the circumstantial evidence, including Verano's confession, the timeline of events, and the possession of the victim's wristwatch, formed a coherent narrative that established Verano's guilt. They contended that the combination of these circumstances was strong enough to exclude any reasonable doubt regarding his involvement in the murder.

  • Defense's Argument: Verano's defense contended that the circumstantial evidence was insufficient to support a conviction. They argued that the evidence did not meet the required standard of moral certainty and that the inconsistencies in witness testimonies undermined the prosecution's case. The defense also highlighted that the other accused were acquitted, suggesting that the evidence against Verano was not compelling.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision to convict Crispolo Verano of murder. It held that the circumstantial evidence presented was sufficient to establish guilt beyond a reasonable doubt. The court outlined that:

  1. There were multiple circumstances linking Verano to the crime, including his presence with the victim, his subsequent actions with the wristwatch, and his confession.
  2. The evidence was consistent and corroborated, forming an unbroken chain of events that pointed to Verano's guilt.
  3. The court found the alleged inconsistencies in witness testimonies to be minor and did not affect their credibility. The court emphasized that minor discrepancies in testimonies do not necessarily undermine the overall reliability of the evidence.

The court also noted that circumstantial evidence could be as compelling as direct evidence, especially when it forms a coherent narrative that excludes reasonable doubt about the defendant's guilt.

Significant Legal Principles Established:

  1. Circumstantial Evidence: The case reaffirmed that circumstantial evidence can be sufficient for conviction if it meets specific criteria: multiple circumstances, proven facts, and a combination that leads to a conclusion of guilt beyond a reasonable doubt.
  2. Credibility of Witnesses: The court reiterated that minor inconsistencies in witness testimonies do not automatically discredit their overall reliability, especially when the testimonies are consistent with the established facts of the case.
  3. Confession as Evidence: The court recognized the weight of a confession, particularly when corroborated by other evidence, in establishing a defendant's guilt.