PEOPLE v. CARLITO ACUÑA

FACTS:

Petitioners Jesus Ramos and Antonio (Tony) Dionisio were charged with the crime of murder for the killing of Tranquilino Mariano. The incident happened on November 22, 1988, in Calumpit, Bulacan. According to the information, Ramos, Dionisio, and their co-accused Carlito Acuña, with intent to kill Mariano, attacked and assaulted him with a bladed instrument, causing him serious physical injuries that resulted in his death. Ramos and Dionisio were arrested and detained on April 17, 1989, while Acuña remained at large. The next day, Ramos and Dionisio filed a motion for admission to bail, but the trial court denied it on June 1, 1989. On June 28, 1989, Ramos and Dionisio pleaded not guilty. Evidence presented during the hearing revealed that Mariano had declined the invitation of the three accused to go with them on two occasions prior to the incident. On the evening of November 22, 1988, Mariano left his house with Ramos, Dionisio, and Acuña while his wife went to sleep. Witnesses later saw Ramos, Dionisio, and Acuña quarreling with Mariano, with Acuña hitting Mariano's head with a piece of wood. As Mariano fell, the three defendants took turns stabbing him with bladed weapons. Mariano's body was later discovered with twelve stab wounds, and a medical examination confirmed that his cause of death was multiple stab wounds and punctured lungs. The trial court eventually convicted Ramos and Dionisio of murder, leading to their appeal before the Supreme Court.

ISSUES:

  1. Whether the credibility of the prosecution witnesses can be questioned by the appellants.

  2. Whether the presence of the prosecution witnesses during the commission of the crime is credible.

RULING:

  1. The Court adheres to the rule that the findings of the trial court on credibility should not be disturbed unless certain facts have been overlooked which would affect the result of the case. The trial judge, having heard the witnesses themselves and observed their deportment and manner of testifying, is in a better position to decide on credibility. Upon review of the records, the Court finds no reason to depart from this rule on credibility.

  2. The presence of the prosecution witnesses during the commission of the crime is credible. It is possible that the appellants and their co-accused were too engrossed in assaulting the victim that they failed to notice the arrival and presence of other persons in the area. There was also a plant between the appellants and the witnesses that obstructed the appellants' view of the witnesses.

PRINCIPLES:

  • The findings of the trial court on credibility should not be disturbed on appeal unless certain facts have been overlooked.

  • The presence of witnesses during the commission of a crime may go unnoticed by the perpetrators if they are too focused on their criminal act.