PEOPLE OF THE PHILIPPINES, vs. ELORDE ANTUD.
- G.R. Number: G.R. No. 95684
- Promulgated: 1992-10-27
- Ponente: Regalado, J.
Doctrine
Findings of the trial court on witness credibility are entitled to great weight because trial judges observe witnesses firsthand; appellate courts should defer absent compelling reason.
Positive identification by eyewitnesses at close range is persuasive evidence of guilt when no motive to fabricate is shown.
Premeditation requires evidence of cool reflection and deliberation between conception of the crime and its commission; such proof must be shown separately.
Facts
Accused-appellant Elorde Antud was charged with murder in Criminal Case No. 2011, R.T.C. Prosperidad, Agusan del Sur, after pleading not guilty and being tried on an information alleging stabbing of Fernando Siega on 24 December 1986.
The prosecution relied on eyewitness testimony: three women who were with the victim and who brought him to the provincial hospital; they positively identified appellant at arm's length.
The case hinged on credibility: the trial court's findings on witness credibility were accorded great weight on appeal.
Issues
Whether the evidence, viewed in light of the credibility findings, established appellant's guilt beyond reasonable doubt.
Whether the element of premeditation was proved.
Ruling
The Court affirmed the appealed decision, holding that the prosecution overcame the presumption of innocence and that appellant's defense was insufficient to raise reasonable doubt.
The Court found that the requisites of premeditation were not present in this case.
The award of indemnity was modified and increased to P50,000.00 in accordance with jurisprudential policy.
Keywords
G.R. No. 95684, murder, intent to kill, treachery, evident premeditation, hunting knife, mortal wounds, instantaneous death, heirs of the said victim, actual compensatory and moral damages, parolee, escaped prisoner, civil liability, medical certificate, perforating stab wound, rebuttal witness, clock, evening, december, elorde antud