G.R. No. 137344 . January 30, 2001.
Fedil Uriarte, Manolito Acosta and Jose Acosta, petitioners, vs. People of the Philippines, respondent.

FACTS

Petitioners Fedil Uriarte, Manolito Acosta, and Jose Acosta were charged with murder for the death of Reynaldo Lamera on August 15, 1992. The prosecution presented eyewitnesses Eric and Nicolas Pacheco, who testified that they saw the three petitioners take turns mauling Lamera, using fists and a piece of wood, which struck him on the neck and thigh, causing him to fall repeatedly until he was lifeless. The initial medical examination by Dr. Jocelyn Laurente, based on visual inspection, concluded death was due to cardio-pulmonary arrest. Suspecting foul play, the victim’s widow requested an autopsy, which was performed months later by NBI medico-legal officer Dr. Tammy Uy after exhumation. Dr. Uy’s autopsy revealed hematomas and concluded the cause of death was “traumatic neck injury.”
The defense presented a different version, claiming Lamera died from a pre-existing heart condition and that the petitioners merely engaged in a friendly scuffle with him. They argued the NBI autopsy was unreliable due to the body’s embalmed state and the time lapse. The trial court convicted petitioners of homicide, not murder, due to the prosecution’s failure to prove treachery or evident premeditation. The Court of Appeals affirmed the conviction.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s factual findings and conviction for homicide.

RULING

The Supreme Court denied the petition and affirmed the conviction. The Court emphasized the well-settled doctrine that factual findings of the trial court, especially when affirmed by the Court of Appeals, are accorded great respect and are generally binding unless they fall under established exceptions, such as being grounded on speculation or manifestly absurd. Here, both lower courts found the testimonies of eyewitnesses Eric and Nicolas Pacheco to be credible, consistent, and sufficient to establish that petitioners’ collective acts of mauling the victim directly caused his death.
The Court rejected the defense’s theory of death by natural causes. It gave greater weight to the autopsy findings of Dr. Tammy Uy, which objectively identified traumatic injuries consistent with the eyewitness accounts, over the initial superficial examination by Dr. Laurente. The petitioners failed to demonstrate any compelling reason, such as grave abuse of discretion or misapprehension of facts, to warrant a reversal of the concurrent factual assessments. Thus, the homicide conviction, with its corresponding penalties and awards for civil indemnity and moral damages, was upheld.