In Philippine jurisprudence, the burden of proving guilt beyond reasonable doubt rests upon the prosecution. This principle was firmly upheld in People of the Philippines v. Bonifacio Dandanon y Iligan a.k.a. Boning, where the Supreme Court affirmed the conviction of the accused for murder. The Court emphasized the credibility of eyewitness testimony and the establishment of treachery in the commission of the crime, illustrating the stringent standards required for a murder conviction. This case serves as a reminder that positive identification by credible witnesses, coupled with evidence of premeditation, can overcome an alibi and secure a conviction.

Crossfire Testimony: How Eyewitness Accounts Secured a Murder Conviction

The case revolves around the murder of Prosecutor Godofredo R. Paceño, Jr., who was shot on April 7, 2006, while riding in a multicab in Butuan City. Bonifacio Dandanon y Iligan, the accused-appellant, was identified by two eyewitnesses as the perpetrator. The Regional Trial Court (RTC) found Dandanon guilty of murder, a decision affirmed with modifications by the Court of Appeals. Dissatisfied, Dandanon appealed to the Supreme Court, questioning the credibility of the eyewitnesses and raising an alibi as his defense.

At the heart of the Supreme Court’s decision was the unwavering credibility it accorded to the eyewitness testimonies. The Court reiterated the principle that findings of fact by the trial court, especially when affirmed by the Court of Appeals, are generally binding. In this case, both lower courts found the testimonies of Gretchen Zaldivar and Joanne Ruales to be credible, as they positively identified Dandanon as the shooter. Their consistent accounts, coupled with the absence of any ill motive, were pivotal in establishing Dandanon’s guilt beyond a reasonable doubt. The court cited People v. Lolos, emphasizing that the trial court’s assessment of witness demeanor is entitled to the highest respect.

Prevailing jurisprudence uniformly holds that findings of fact of the trial court, particularly when affirmed by the Court of Appeals, are binding upon this Court. As a general rule, on the question whether to believe the version of the prosecution or that of the defense, the trial court’s choice is generally viewed as correct and entitled to the highest respect because it is more competent to conclude so, having had the opportunity to observe the witnesses’ demeanor and deportment on the witness stand as they gave their testimonies.

The Supreme Court also delved into the qualifying circumstance of treachery, which elevated the crime from homicide to murder. Article 248 of the Revised Penal Code defines murder and specifies the circumstances that qualify a killing as such. Treachery, or alevosia, exists when the offender employs means to ensure the execution of the crime without risk to themselves arising from the defense the offended party might make. The elements of treachery were evident in Dandanon’s actions: he armed himself, boarded the same vehicle as Paceño, and, without warning, shot the victim twice in the head.

Art. 248. Murder. – Any person who, not falling within the provisions of Article 246, shall kill another, shall be guilty of murder and shall be punished by reclusion perpetua, to death if committed with any of the following attendant circumstances:
1. With treachery, taking advantage of superior strength, with the aid of armed men, or employing means to weaken the defense, or of means or persons to insure or afford impunity[.]

Dandanon raised an alibi, claiming he was in Sibagat, Agusan del Sur, at the time of the murder. However, the Court found this defense unconvincing. To successfully invoke alibi, an accused must demonstrate that they were in another place during the commission of the crime and that it was physically impossible for them to be at the crime scene. Given the relatively short distance between Sibagat and Butuan City, it was not physically impossible for Dandanon to be present at the scene of the crime. The Court also highlighted the importance of positive identification, stating that it prevails over alibi, especially when no ill motive is attributed to the prosecution witnesses.

Furthermore, the Court addressed Dandanon’s argument that his non-flight indicated innocence. The Court clarified that non-flight is not conclusive proof of innocence, unlike flight, which can be considered evidence of guilt. Non-flight is considered inaction, and can be attributed to many reasons, it does not automatically equate to innocence. This distinction underscores the principle that the absence of evidence of guilt does not necessarily equate to proof of innocence.

In determining the appropriate penalties and monetary awards, the Supreme Court affirmed the sentence of reclusion perpetua. The Court also recalculated the award for loss of earning capacity, using a specific formula to determine the net earning capacity of the deceased. Moreover, the Court increased the amounts awarded for civil indemnity and moral damages, aligning with prevailing jurisprudence. This adjustment reflects the Court’s recognition of the severe emotional distress and financial losses suffered by the victim’s heirs.

FAQs

What was the key issue in this case?	The central issue was whether the prosecution successfully proved Dandanon’s guilt beyond a reasonable doubt for the crime of murder, considering the eyewitness testimonies, the defense of alibi, and the presence of treachery.
What is the definition of treachery in the context of murder?	Treachery (alevosia) is the employment of means, methods, or forms of execution that tend directly and specially to ensure the offender’s safety from any defensive or retaliatory act on the part of the offended party. It involves a swift and unexpected attack on an unarmed victim without provocation.
Why was Dandanon’s alibi not accepted by the court?	Dandanon’s alibi failed because he could not prove that it was physically impossible for him to be at the crime scene. The distance between Sibagat and Butuan City was not so great as to preclude his presence at the time of the murder.
What is the significance of positive identification in criminal cases?	Positive identification, when categorical, consistent, and without any ill motive on the part of the eyewitnesses, prevails over alibi and denial. It is a crucial factor in establishing the guilt of the accused.
What is the difference between flight and non-flight in terms of evidence?	Flight is considered evidence of guilt, implying an attempt to evade justice. Non-flight, however, is not conclusive proof of innocence, as it can be attributed to various reasons other than innocence.
How is the loss of earning capacity calculated in murder cases?	The loss of earning capacity is calculated using a formula that considers the victim’s remaining life expectancy, gross annual income, and living expenses. The formula is: Net Earning Capacity = [2/3 (80 – age at death)] x (Gross Annual Income – 50% of Gross Annual Income).
What are civil indemnity, moral damages, and exemplary damages?	Civil indemnity is automatically imposed upon the accused for the commission of the crime. Moral damages are awarded for the mental anguish suffered by the heirs of the deceased. Exemplary damages are awarded as a form of punishment and to set an example.
What was the final decision of the Supreme Court in this case?	The Supreme Court affirmed the conviction of Dandanon for murder, sentencing him to reclusion perpetua and ordering him to pay the heirs of Paceño for loss of earning capacity, civil indemnity, moral damages, and exemplary damages.

The Supreme Court’s decision in People v. Dandanon underscores the importance of credible eyewitness testimony and the rigorous application of legal principles in murder cases. This ruling serves as a clear guideline for prosecutors and defense attorneys alike, illustrating the weight given to positive identification and the challenge of successfully asserting an alibi. It also reinforces that establishing the presence of treachery significantly impacts the severity of the conviction.

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. BONIFACIO DANDANON Y ILIGAN, G.R. No. 196258, September 28, 2015