In People vs. Dadao, the Supreme Court affirmed the conviction of Marcelino Dadao, Antonio Sulindao, and Alfemio Malogsi for murder, emphasizing the reliability of eyewitness testimony and the principle of conspiracy. The court underscored that even minor inconsistencies in witness statements do not diminish their credibility when they consistently identify the accused. This ruling reinforces the importance of positive identification in Philippine criminal law and clarifies the application of damages in murder cases, ensuring justice for victims and their families. The decision serves as a reminder of the severe consequences of conspiracy in criminal acts and the weight given to eyewitness accounts.

When Witness Accounts and Concerted Actions Determine Guilt

This case stems from the tragic murder of Pionio Yacapin on July 11, 1993, in Bukidnon, Philippines. Marcelino Dadao, Antonio Sulindao, Eddie Malogsi (deceased during the appeal), and Alfemio Malogsi were charged with conspiring to kill Yacapin with firearms and bolos. The central legal question revolves around the credibility of the prosecution’s eyewitnesses—Yacapin’s stepsons and widow—and the validity of the accused’s alibis. The case also examines the application of treachery as a qualifying circumstance for murder and the implications of conspiracy among the accused.

The Regional Trial Court found the appellants guilty beyond reasonable doubt, a decision that was later affirmed with modifications by the Court of Appeals. The prosecution presented testimonies from Ronie and Edgar Dacion, stepsons of the victim, and Nenita Yacapin, the victim’s widow, who all positively identified the appellants as the perpetrators. Their testimonies recounted how the appellants attacked Yacapin in his house, using firearms and bolos.

The defense attempted to discredit the prosecution’s case by presenting alibis and highlighting inconsistencies in the witness testimonies. They also pointed to negative results from paraffin tests conducted on the accused. However, the courts found these defenses insufficient to overcome the positive identification made by the prosecution’s witnesses. The Supreme Court, in its review, emphasized the principle that factual findings of the trial court, especially concerning witness credibility, are generally upheld unless there is a clear misapprehension of facts. As the Supreme Court stated in People v. De la Rosa:

[T]he issue raised by accused-appellant involves the credibility of [the] witness, which is best addressed by the trial court, it being in a better position to decide such question, having heard the witness and observed his demeanor, conduct, and attitude under grueling examination. These are the most significant factors in evaluating the sincerity of witnesses and in unearthing the truth, especially in the face of conflicting testimonies. Through its observations during the entire proceedings, the trial court can be expected to determine, with reasonable discretion, whose testimony to accept and which witness to believe.

Building on this principle, the Supreme Court underscored that when prosecution witnesses are not shown to have any ill motives, their testimonies are entitled to full faith and credit. In this case, the appellants failed to demonstrate any improper motive on the part of the witnesses, further bolstering the credibility of their accounts. The Court also addressed the alleged inconsistencies in the testimonies, noting that these were minor details that did not detract from the overall probative value of the witnesses’ positive identification of the appellants.

The defense of alibi, presented by the appellants, was also deemed insufficient. Philippine jurisprudence firmly establishes that positive identification prevails over alibi, especially when the alibi is not supported by credible corroboration from disinterested witnesses. In this instance, the appellants’ alibis were either uncorroborated or supported by biased witnesses, such as friends and relatives.

The Supreme Court also addressed the significance of the negative paraffin test results. It reiterated the established legal principle that a paraffin test is not conclusive proof that a person did not fire a gun. Moreover, the prosecution’s evidence indicated that only two of the appellants, Eddie and Alfemio Malogsi, purportedly used firearms, while the others used bolos. Consequently, the negative results for Marcelino Dadao and Antonio Sulindao did not undermine the prosecution’s case.

Central to the Court’s decision was the finding of conspiracy among the appellants. The evidence demonstrated a concerted action and a shared criminal design to murder Pionio Yacapin. The Court invoked the principle that once conspiracy is established, the act of one conspirator is the act of all. As explained in People v. Nelmida:

There is conspiracy when two or more persons come to an agreement concerning the commission of a felony and then decide to commit it. It arises on the very instant the plotters agree, expressly or impliedly, to commit the felony and forthwith decide to pursue it. Once established, each and every one of the conspirators is made criminally liable for the crime actually committed by any one of them. In the absence of any direct proof, the agreement to commit a crime may be deduced from the mode and manner of the commission of the offense or inferred from acts that point to a joint purpose and design, concerted action, and community of interest. As such, it does not matter who inflicted the mortal wound, as each of the actors incurs the same criminal liability, because the act of one is the act of all.

The Court also dismissed the argument that the appellants’ voluntary surrender to the police indicated their innocence. Citing jurisprudence, the Court noted that non-flight does not necessarily connote innocence, as culprits may behave in various ways to mask their guilt.

Furthermore, the Supreme Court affirmed the lower court’s appreciation of treachery as a qualifying circumstance for murder. Treachery exists when the offender employs means to ensure the execution of the crime without risk to themselves from the victim’s defense. The Court agreed with the Court of Appeals’ finding that the attack on Pionio Yacapin was executed in a manner that afforded him no chance to defend himself.

The Court also addressed the issue of damages. It affirmed the award of civil indemnity and temperate damages but modified the amounts of moral and exemplary damages to align with prevailing jurisprudence. Additionally, the Court clarified the effect of Eddie Malogsi’s death during the pendency of the case. Citing Article 89(1) of the Revised Penal Code and People v. Bayotas, the Court ruled that the death of an accused before final judgment extinguishes both criminal and civil liability, leading to the dismissal of the case against Malogsi.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution presented sufficient evidence, particularly eyewitness testimonies, to prove the guilt of the accused beyond reasonable doubt for the murder of Pionio Yacapin. The case also considered the validity of the accused’s alibis and the applicability of treachery and conspiracy.
What is the significance of eyewitness testimony in this case?	Eyewitness testimony from the victim’s stepsons and widow was crucial in identifying the accused as the perpetrators. The Court emphasized that positive identification by credible witnesses is a strong basis for conviction, especially when the witnesses have no apparent motive to falsely accuse the defendants.
How did the Court address inconsistencies in witness testimonies?	The Court acknowledged minor inconsistencies in the witnesses’ statements but deemed them immaterial and insignificant. It emphasized that as long as the testimonies corroborated each other on material points, the minor inconsistencies did not undermine the witnesses’ credibility.
Why was the defense of alibi rejected?	The defense of alibi was rejected because it was not supported by credible corroboration from disinterested witnesses. Philippine jurisprudence requires that alibis be substantiated by reliable and impartial evidence to be given weight, which was lacking in this case.
What is the legal implication of conspiracy in this case?	The finding of conspiracy meant that all the accused were held equally liable for the crime of murder, regardless of who directly inflicted the fatal wounds. Once conspiracy is established, the act of one conspirator is considered the act of all.
How did the negative paraffin test results affect the outcome of the case?	The negative paraffin test results did not significantly affect the outcome because the Court recognized that a paraffin test is not conclusive evidence that a person did not fire a gun. Additionally, only some of the accused were alleged to have used firearms.
What was the Court’s ruling on the aggravating circumstance of treachery?	The Court affirmed the lower court’s appreciation of treachery as a qualifying circumstance, noting that the attack was deliberate and without warning, giving the victim no chance to defend himself. This element elevated the crime to murder.
What were the modifications made to the award of damages?	The Supreme Court modified the amounts of moral and exemplary damages to align with current jurisprudence. It also imposed a legal interest rate of six percent per annum on all damages from the date of finality of the judgment.
What was the effect of Eddie Malogsi’s death during the appeal?	The death of Eddie Malogsi during the pendency of the appeal extinguished his criminal and civil liability. The Court dismissed the case against him in accordance with Article 89(1) of the Revised Penal Code and relevant jurisprudence.

The Supreme Court’s decision in People vs. Dadao reinforces key principles of Philippine criminal law, including the importance of eyewitness testimony, the consequences of conspiracy, and the application of damages in murder cases. The ruling serves as a significant precedent for future cases involving similar factual circumstances and legal issues. This case demonstrates the meticulous approach taken by Philippine courts in ensuring justice for victims of violent crimes while adhering to established legal doctrines.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People of the Philippines vs. Marcelino Dadao, G.R. No. 201860, January 22, 2014