GR 125533; (December, 2000) (Digest)
G.R. No. 125533 ; December 27, 2000
People of the Philippines, plaintiff-appellee, vs. Jimmy Alo and Leonardo An, accused. Jimmy Alo, accused-appellant.
FACTS
Accused-appellant Jimmy Alo, together with his co-accused Leonardo An who remained at-large, was charged with the murder of Alfredo Cantos. The prosecution alleged that on October 23, 1992, in Rosario, Batangas, the accused, armed with bolos, conspired to hack the victim suddenly and without warning, causing his death. The prosecution’s case primarily rested on the eyewitness account of the victim’s son, Christopher Cantos, who testified that he saw both Alo and An attack his father while they were drinking. His testimony was corroborated by Marina Nolial. The defense, however, presented a different version. Appellant Alo denied participation, testifying that he was inside Nolial’s house and merely witnessed Leonardo An alone perpetrate the hacking.
ISSUE
The core issue is whether the prosecution proved the guilt of accused-appellant Jimmy Alo for the crime of murder beyond reasonable doubt, amidst challenges to the credibility of the prosecution witnesses.
RULING
The Supreme Court affirmed the conviction but modified the damages. The Court found no merit in the appeal, holding that the alleged inconsistencies in the testimonies of prosecution witnesses Christopher Cantos and Marina Nolial pertained to minor and trivial details that did not undermine the essential consistency of their narratives regarding the principal occurrence—that both accused-appellant and his co-accused hacked the victim. The Court emphasized that minor discrepancies are common and even indicate truthfulness, as they show that testimonies were not rehearsed. The positive and categorical identification by the eyewitness, who had no ill motive to falsely testify, prevailed over appellant’s bare denial. The qualifying circumstance of treachery was duly established, as the attack was sudden and unexpected, depriving the victim of any chance to defend himself. The Court rejected the claim of voluntary surrender as a mitigating circumstance, finding that appellant’s arrest was facilitated by a police officer and was not spontaneous. The penalty of reclusion perpetua was affirmed. However, the Court recalculated the awarded damages, reducing actual damages to only the amount substantiated by receipts (P20,544.00) and properly computing lost earning capacity using the standard formula, resulting in an increased award of P583,524.00.