CAPISTRANO DAAYATA v. PEOPLE

FACTS:

The case involves a petition for review on certiorari to reverse the decision and resolution of the Court of Appeals which affirmed the conviction of the petitioners for frustrated murder. The petitioners, Capistrano Daayata, Dexter Salisi, and Bregido Malacat, were charged with frustrated murder for allegedly attacking and assaulting Rolando Bahian with the intent to kill him. According to the prosecution, Bahian had a confrontation with Salisi during a basketball game, and the following day, petitioners blocked Bahian and assaulted him with various weapons, leading to his injuries. On the other hand, the defense claimed that Bahian initiated a fight with Salisi, causing him to lose his balance and hit his head on the pavement. The defense also alleged that Bahian and Kagawad Abalde, who was present during the incident, threatened the petitioners with a gun.

The case involves a petition for review on certiorari filed by three individuals (Capistrano Daayata, Dexter Salisi, and Bregido Malacat, Jr.) who were charged and found guilty of frustrated murder. The incident stemmed from an altercation that occurred during a basketball game between the petitioners and the victim, Rolando Bahian. The following day, while the petitioners were on their way home, Bahian allegedly challenged them to a fight, to which they claim to have pacified him. However, a confrontation ensued later that evening, during which the petitioners allegedly attacked Bahian. The Regional Trial Court found the petitioners guilty of frustrated murder and sentenced them to imprisonment and ordered them to pay damages to Bahian. The Court of Appeals later affirmed the trial court's decision with modifications on the damages awarded. The petitioners filed the present petition insisting on their version of events and seeking the reversal of their conviction. They argue that Bahian's injury was due to his own fault and that they should not be held liable for attempted murder.

ISSUES:

  1. Whether there has been a gross misapprehension of facts on the part of the Regional Trial Court and the Court of Appeals.

  2. Whether the alleged assault and infliction of a potentially fatal injury by the petitioners have been adequately proven.

  3. Whether the admission made by the complainant to his doctor, stating that he hit his head on the edge of the pavement, diminishes the weight of his testimony.

  4. Whether the defense witnesses' testimonies, which contradict the prosecution's claim that the accused were armed with a gun, bolo, and iron bar, discredit the prosecution's case.

  5. Whether the prosecution has established the moral certainty and conscientious satisfaction required to prove guilt beyond reasonable doubt.

  6. Whether there is doubt as to the veracity of the complainant's version of events.

  7. Whether the complainant was relentlessly assaulted for the purpose of ending his life.

  8. Whether the petitioners actually brandished implements for maiming and killing.

RULING:

  1. The Supreme Court, upon careful review of the case and the evidence presented, found that there was a gross misapprehension of facts by the lower courts. As a result, the Court reversed and acquitted the petitioners. The Court also noted that the defense presented facts that cast doubt on the prosecution's claim of assault and infliction of a potentially fatal injury. The lack of specificity in the location of the altercation, the absence of other injuries aside from the one on the victim's forehead, and the victim's admission that his head injury was caused by hitting the edge of the concrete pavement all contributed to the Court's ruling of acquittal.

  2. The admission made by the complainant to his doctor, stating that he hit his head on the edge of the pavement, does not diminish the weight of his testimony. The defense's revelation that the complainant's alleged lie was not based on a rational basis stands unrefuted.

  3. The testimonies of the defense witnesses, including the prosecution's own witness, stating that they did not see the accused armed with a gun, bolo, or iron bar, cast doubt on the prosecution's claim. The burden of proof rests on the prosecution to prove the guilt of the accused beyond reasonable doubt, and their failure to do so entitles the accused to an acquittal.

  4. The Petition is granted and the decision of the Court of Appeals is reversed. The petitioners are acquitted due to the failure of the prosecution to prove their guilt beyond reasonable doubt. It is also ordered that any amount paid by the petitioners by way of bail bond be returned.

PRINCIPLES:

  • The factual findings of lower courts are generally binding and conclusive on the Supreme Court, but there are exceptions permitting the Supreme Court to overturn such findings.

  • In criminal cases, the Supreme Court may re-evaluate the factual findings of lower courts in exceptional circumstances, such as when the trial court overlooked material and relevant matters.

  • Physical evidence is considered evidence of the highest order and speaks more eloquently than witness testimonies.

  • In the absence of marked physical injuries, the Court cannot easily lend credence to claims of perpetration of physical violence.

  • Conflicting or inconsistent factual findings can be grounds for overturning the lower court's decision.

  • Admissions made during cross-examination can be considered as evidence when evaluating the credibility of a witness's testimony.

  • Conviction in criminal actions demands proof beyond reasonable doubt.

  • The prosecution carries the burden of establishing the guilt of the accused, relying on the strength of its own evidence.

  • Proof beyond reasonable doubt does not require absolute certainty, but moral certainty.

  • The conviction of the accused must rest on the strength of the prosecution's evidence, not on the weakness of the defense.

  • The burden of proof is on the prosecution, and unless it discharges that burden, the accused is entitled to an acquittal.

  • The prosecution must establish the moral certainty and conscientious satisfaction required to prove guilt beyond reasonable doubt.

  • Doubts as to the veracity of the complainant's version of events may cast doubt on the prosecution's case.

  • The prosecution must prove that the complainant was relentlessly assaulted for the purpose of ending his life.

  • The prosecution must prove that the petitioners brandished implements for maiming and killing.