Facts:
On March 20, 1983, during a barangay fiesta in Catbalogan, Samar, Philippines, Tiburcio Abalos, also known as “Ewet”, was accused of assaulting and killing Pfc. Sofronio Labine, a member of the Integrated National Police (INP), with a piece of wood. Labine suffered fatal injuries, including a severe skull fracture.
On April 21, 1983, an Information was filed charging Abalos with the complex crime of direct assault with murder. At the arraignment on June 7, 1983, Abalos pleaded not guilty, which led to a trial before the Regional Trial Court (RTC), Branch 27, of Catbalogan, Samar.
The case went through the standard trial procedure in the RTC where the prosecution presented Felipe Basal as a witness. He testified to having seen Abalos strike Labine with a piece of wood near Abalos’s residence. Abalos, in his defense, claimed that he mistakenly believed his father was being attacked by a member of the New People’s Army (NPA) and was acting in defense when he struck Labine, whom he did not recognize in the moment.
The RTC found Abalos guilty as charged on February 3, 1989, and sentenced him to life imprisonment (later corrected to reclusion perpetua), ordering him to also pay compensatory damages to the heirs of the victim. Not convinced by the court’s decision, Abalos appealed to the Supreme Court of the Philippines.
Issues:
1. Whether the RTC erred in believing the sole prosecution witness over the defense’s account.
2. Whether the prosecution’s evidence met the required quantum of evidence for a conviction.
3. Whether treachery was present in the commission of the crime.
4. Whether Abalos should have been credited for voluntary surrender.
5. Determining the accuracy of the RTC’s assessment regarding the aggravating circumstances and the proper penalty.
Court’s Decision:
The Supreme Court sided with the trial court and affirmed the conviction. Justice Regalado analyzed the case’s merits and found the testimony of the prosecution’s witness to be credible and sufficient for conviction. The Supreme Court found no evidence of any improper motive by the witness to testify against Abalos.
Regarding the legal issues:
1. Justice Regalado found no merit in Abalos’s claim that the trial court should not have credited the lone eyewitness, as an eyewitness’s testimony, if credible, is sufficient for conviction.
2. The Court held that the evidence standard was met based on the positive and clear testimony from the prosecution’s witness.
3. The killing was found to be murder qualified by treachery, as Abalos struck Labine from behind, intending to ensure his own safety by avoiding retaliation from the police officer.
4. Although the Court mentioned Abalos’s voluntary surrender, it was rendered immaterial since the prescribed penalty for the more severe offense in a complex crime is always in the maximum period.
5. The Supreme Court corrected the RTC’s imposition of life imprisonment to reclusion perpetua and raised the death indemnity to P50,000 from P30,000, in line with current jurisprudential policy.
Doctrine:
The case reaffirmed the doctrine that the testimony of a single, credible and positive eyewitness is sufficient for conviction. It also illustrated the application of the complex crime of direct assault with murder, where the assault on a person in authority leads to murder, resulting in a complex crime where the penalty for the graver offense is imposed in the maximum period. The doctrine was also applied that treachery (alevosia) and deliberate means of assault can qualify a killing as murder.
Class Notes:
– In crimes of direct assault, the accused must have intent to offend, injure, or assault the person in authority or agent.
– To commit murder, there must be an element of treachery where the means of execution ensured no risk to the offender from the victim’s defense.
– The penalty for complex crimes is for the graver offense in its maximum period.
– A voluntary surrender may be considered a mitigating circumstance but is not applicable if the penalty is indivisible, as in the case of murder or complex crimes involving murder at the time of this decision.
Historical Background:
This case took place at a time in Philippine history when the country’s legal system was grappling with instability and threats from insurgent groups. The fact that Abalos claimed he believed his father was under attack by the NPA contextualizes the period’s security issues. This was during the presidency of Ferdinand Marcos when uprisings and violence were relatively common, and law enforcement officers like Labine were at particular risk. The Supreme Court’s decision underscores the legal system’s efforts to maintain order and uphold the rule of law amidst such challenges.
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