Credibility of witnesses; trial courts

In Candoy v. People (G.R. No. 238606, October 10, 2018), petitioners hinge their appeal on alleged inconsistencies and improbabilities marring the testimony of the prosecution's witnesses. Petitioners further argue that the evidence failed to establish conspiracy and the aggravating circumstance of abuse of superior strength.

Unfortunately, petitioners resorted to a Rule 45 petitions and the issues raised are factual and evidentiary in nature. They are outside the Supreme Court's scope of review in Rule 45 petitions. In this regard, it is settled that the assessment of the credibility of witnesses is a task most properly within the domain of trial courts due to the unique opportunity afforded them to observe the witnesses when placed on the stand. While questions of fact have been entertained by the Court in justifiable circumstances, petitioners failed to establish that the instant case falls within the allowable exceptions. Hence, not being a trier of facts but of law, the Supreme Court must necessarily defer to the concurrent findings of fact of the CA and the Regional Trial Court.

After reviewing the petition and its annexes, it was found in this case that the CA committed no reversible error in finding petitioners guilty of Attempted Murder.As correctly observed by the CA, petitioners' prior and simultaneous acts unquestionably indicate a unity of purpose between his co-accused in the execution of an unlawful objective. Weighed against the self-serving and uncorroborated testimonies of petitioners, the positive testimonies of the witnesses, as confirmed by the physical evidence, clearly establish beyond reasonable doubt that petitioners and their co-accused were driven by a common objective of killing the private complainant and that they had taken advantage of their number in their means of attack.

However, anent the award of damages, considering that the crime committed is Attempted Murder, the civil indemnity, moral damages, and exemplary damages are accordingly modified to P25,000.00 each, following recent jurisprudence.

[1] See People v. Gahi, 727 Phil. 642, 658 (2014).
[2] See Miro v. Vda. de Erederos, 721 Phil. 772, 785-786 (2013).
[3] People v. Jugueta, 783 Phil. 806 (2016).