View full case

RICKY BASTIAN v. CA

FACTS:

In this case, Ricky Bastian was found guilty of homicide by the Regional Trial Court (RTC). The Court of Appeals (CA) affirmed the RTC's decision with modification. The events occurred on April 24, 1995, when Lorna Bandiola witnessed Ricky Bastian shoot John Ronquillo. The police officers who investigated the incident found Ronquillo's dead body with gunshot wounds. Ricky Bastian and his co-accused were indicted for murder based on the autopsy report. During the trial, the prosecution presented testimonies to establish their case, while Ricky Bastian's defense was denial supported by witnesses testifying to his alibi.

On appeal, the trial court convicted Ricky Bastian of homicide instead of murder and acquitted the other accused due to insufficient evidence. The court sentenced Ricky Bastian to imprisonment and ordered him to pay indemnity and damages to the victim's heirs. Dissatisfied, Ricky Bastian appealed to the CA, which affirmed the trial court's decision but modified the damages awarded. Ricky Bastian then filed a petition before the Supreme Court, raising errors committed by the CA in affirming the trial court's decision.

In another case, John Ronquillo was shot and killed inside his house, witnessed by his partner Vilma Dagdag. Fortunato Punzalan Jr. was identified as the shooter, but he denied any involvement in the crime. During the trial, the prosecution presented witnesses, including Vilma Dagdag, who positively identified the accused. The defense presented witnesses claiming that the accused was somewhere else at the time of the shooting. The trial court found the accused guilty of murder based on the positive identification and rejected the defense's alibi. The accused appealed to the CA, arguing that the trial court erred in giving weight to the prosecution's evidence and disregarding the defense's alibi. The CA affirmed the trial court's decision, stating that the accused was positively identified and the defense's evidence was insufficient. The accused filed a petition for review before the Supreme Court, reiterating the defense of mistaken identity and questioning the reliability of the witness due to alleged involvement of the New People's Army (NPA) in the killing.

ISSUES:

  1. Whether the testimonies of the prosecution witnesses are credible and worthy of belief.

  2. Whether the claim of the New People's Army (NPA) for the killing of the victim is binding on the court.

  3. Whether the conviction of the petitioner based on circumstantial evidence is valid.

  4. Whether the circumstantial evidence presented sufficiently identified the petitioner as the author of the killing.

  5. Whether the testimony of a single credible and positive eyewitness is sufficient to support a conviction.

RULING:

  1. The court finds no cogent reason to depart from the findings and conclusions reached by the trial court and the Court of Appeals (CA). The credibility of witnesses is best determined by the trial and appellate courts. The testimonies of the prosecution witnesses are deemed credible and have met the tests of credibility and believability.

  2. The claim of the NPA for the killing of the victim is not binding on the court. It does not preclude the court from determining the real killer based on the rules of evidence and settled jurisprudence.

  3. The court finds that the conviction of the petitioner based on circumstantial evidence is valid. Circumstantial evidence is admissible and can lead to a conviction when direct evidence is lacking. The requisites for circumstantial evidence to support a conviction have been met.

  4. The unbroken chain of circumstances, consisting of the testimony of an eyewitness who heard gunshots, saw the petitioner with a gun shortly thereafter, and found the victim dead in the area where the gunshots were heard, sufficiently identified the petitioner as the assailant. The combination of these circumstances, taken collectively, engendered moral certainty for the court to believe that the petitioner was the assailant.

  5. The testimony of a single witness, if positive and credible, is sufficient to support a conviction, even in a charge of murder. Therefore, even if one eyewitness's testimony is disregarded, the conviction of the petitioner based on the positive declarations of another eyewitness still stands on firm ground.

PRINCIPLES:

  • The determination of the credibility of witnesses is best left to the trial and appellate courts.

  • The claim of responsibility by a third party does not bind the court in determining the guilt of the accused.

  • The findings of the trial court on credibility are accorded great weight and respect.

  • Circumstantial evidence is admissible and can lead to a conviction if the requisites for its sufficiency are met.

  • In determining the value and credibility of evidence, witnesses are to be weighed, not numbered.

  • Truth is established not by the number of witnesses but by the quality of their testimonies.

  • The penalty for homicide is reclusion temporal in any of its periods, ranging from twelve (12) years and one (1) day to twenty (20) years.

  • The aggravating circumstance of nighttime does not aggravate the killing if it is not relevant to its commission.

  • Under the Indeterminate Sentence Law, the minimum term must be taken from the penalty next lower in degree, which is prision mayor, ranging from six (6) years and one (1) day to twelve (12) years.

  • Awards for burial expenses, lost earnings, civil indemnity, and moral damages in accordance with latest jurisprudence are upheld.