People of the Philippines Vs. Samson Berk Bayogan
G.R. No. 204896. December 7, 2016

Appellant and his co-accused Jeneto Serencio (Serencio) were charged before the RTC of Lingayen, Pangasinan, Branch 39 with murder as follows:

That on or about 10:45 o'clock in the morning of December 16, 2007, in Poblacion East, Sual, Pangasinan and within the jurisdiction of this Honorable Court, the above-named accused, conspiring and confederating with each other with treachery and with intent to kill, did then and there, wilfully, unlawfully and feloniously attack, and shot Clarita Disu several times, inflicting upon her several gunshot wounds which [caused] her instantaneous death, to the damage and prejudice of her heirs.

Contrary to Article 248 of the Revised Penal Code in relation to RA 7659 as amended.

The prosecution presented eyewitnesses Marbie S. Disu (Marbie) and Loreto Inocencio (Loreto) , respectively the daughter and grandson of the victim. Their testimonies established that in the morning of 16 December 2007, the victim Clarita Disu and her daughter Marbie were tending their neighbourhood variety store in Sual, Pangasinan with Loreto, when two (2) men on board a motorcycle arrived. One dismounted the vehicle and bought a cigarette from Marbie while the other stayed on the vehicle. The man who bought the cigarette suddenly pulled a gun and pointed it to Clarita and shot her four (4) times. Marbie shouted for help and ran to the fallen victim to help and embrace her. The assailant, who had been wearing a yellow t-shirt, then boarded the motorcycle and headed east. Marbie noted the motorcycle plate number as AR 3273.

During arraignment, appellant pleaded not guilty to the crime charged. Serencio remains at large. Trial on the merits thereafter ensued.


1.    What are the elements of murder?

In the prosecution of the crime of murder as defined in Article 248 of the Revised Penal Code (RPC), the following elements must be established by the prosecution: (1) that a person was killed; (2) that the accused killed that person; (3) that the killing was attended by treachery; and (4) that the killing is not infanticide or parricide.


2.    The accused invoked defenses of denial and alibi. Will the defense prosper?

The defenses of denial and alibi as these cannot prevail over the eyewitnesses' positive identification of him as the perpetrator of the crime. Denial, like alibi, if not substantiated by clear and convincing evidence is negative and self-serving evidence undeserving of weight in law.


3.    Is the element of treachery present in this case?

Yes.

The shooting of the unsuspecting victim was sudden and unexpected which effectively deprived her of the chance to defend herself or to repel the aggression, insuring the commission of the crime without risk to the aggressor and without any provocation on the part of the victim.


4.    Discuss the weight of the findings of the trial court on the credibility of witnesses?

Well-settled in our jurisprudence is the rule that findings of the trial court on the credibility of witnesses deserve great weight, as the trial judge is in the best position to assess the credibility of the witnesses, and has the unique opportunity to observe the witness first hand and note his demeanor, conduct and attitude under gruelling examination.


5.    Should the trial judge who penned the Decision be the one to receive the evidence?

No.

The fact that the trial judge who penned the Decision was different from the one who received the evidence does not render the same erroneous. It is not necessary for a judgment to be valid that the judge who penned the decision should actually hear the case in its entirety, for he can merely rely on the transcribed stenographic notes taken during the trial as the basis for his decision.

Absent any showing that the trial court's findings of facts were tainted with arbitrariness or that it overlooked or misapplied some facts or circumstances of significance and value, or its calibration of credibility was flawed, the appellate court is bound by its assessment.


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