PEOPLE OF THE PHILIPPINES, vs. DELFIN MOLINA AND ADOLFO MOLINAs.
- G.R. Number: G.R. No. 59436
- Promulgated: 1992-08-28
- Ponente: Bidin, J.
Doctrine
An eyewitness account that corresponds with autopsy findings is credible and may establish guilt beyond reasonable doubt.
Appellate courts generally defer to the trial court on issues of witness credibility absent overlooked facts or circumstances.
Treachery exists where the attack is sudden, swift, and the victim, unarmed and unsuspecting, is assaulted by assailants acting together.
Facts
This is an appeal from the 7 November 1981 decision of the Court of First Instance of Abra convicting appellants Adolfo and Delfin Molina of Murder and sentencing them to reclusion perpetua with civil indemnities and damages.
Appellants challenged identification, alleging inconsistencies in the testimony that cast doubt on positive identification of the assailants.
Autopsy evidence showed multiple wounds from blunt instrument and bolo; number and locations of wounds indicated more than one assailant, tending to corroborate eyewitness accounts.
Eyewitness Clara Molina described a swift, three-minute attack: Adolfo struck with a stone and both brothers hacked the victim with bolos, supporting finding of treachery.
Issues
Whether the identification and testimony established guilt beyond reasonable doubt.
Whether the qualifying circumstance of treachery was properly appreciated.
Ruling
The Court affirmed the trial court's conviction of Adolfo and Delfin Molina for Murder, finding no reversible error in the trial court's credibility determinations.
The conviction was modified as to civil liability: the Court increased the amount to P50,000.00 for the victim's death.