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PEOPLE v. HONORATO C. BELTRAN

This case has been cited 24 times or more.

	GR No. 191721 2011-01-12	PEOPLE v. ROGELIO DOLORIDO Y ESTRADA VELASCO JR., J.
This Court has held in People v. Beltran, Jr. that "[w]hen death occurs due to a crime, the following damages may be awarded: (1) civil indemnity ex delicto for the death of the victim; (2) actual or compensatory damages; (3) moral damages; (4) exemplary damages; and (5) temperate damages."[28]
	GR No. 183094 2010-09-22	PEOPLE v. REYNALDO BARDE PEREZ, J.
Primarily, it has been jurisprudentially acknowledged that when the issues revolve on matters of credibility of witnesses, the findings of fact of the trial court, its calibration of the testimonies of the witnesses, and its assessment of the probative weight thereof, as well as its conclusions anchored on said findings, are accorded high respect, if not conclusive effect. This is because the trial court has the unique opportunity to observe the demeanor of witnesses and is in the best position to discern whether they are telling the truth.[52] In this case, it is notable that the Court of Appeals affirmed the factual findings of the trial court, according credence and great weight to the testimonies of the prosecution witnesses. Settled is the rule that when the trial court's findings have been affirmed by the appellate court, said findings are generally conclusive and binding upon this Court,[53] unless the trial court had overlooked, disregarded, misunderstood, or misapplied some fact or circumstance of weight and significance which if considered would have altered the result of the case.[54] None of these circumstances is attendant in this case. This Court, thus, finds no cogent reason to deviate from the factual findings arrived at by the trial court as affirmed by the Court of Appeals.
	GR No. 188331 2010-06-16	PEOPLE v. RYAN LALONGISIP Y DELOS ANGELES NACHURA, J.
It is a doctrine well settled in our jurisprudence that when the credibility of a witness is in issue, the findings of fact of the trial court, its calibration of the testimonies of the witnesses, and its assessment of the probative weight thereof, as well as its conclusions anchored on said findings, are accorded high respect, if not conclusive effect. This is because the trial court has the unique opportunity to observe the demeanor of witnesses and is in the best position to discern whether they are telling the truth. It is worth stressing that the CA affirmed the RTC's findings, according credence and great weight to the testimonies of the prosecution's witnesses. In this regard, it is the rule that when the trial court's findings have been affirmed by the appellate court, said findings are generally conclusive and binding upon this Court.[13] We find no compelling reason to deviate from the uniform finding of both the RTC and the CA that indeed appellant is guilty beyond reasonable doubt of the crime of Murder.
	GR No. 181071 2010-03-15	LADISLAO ESPINOSA v. PEOPLE PEREZ, J.
People v. Beltran, Jr.,[13] which also involves repetitious hacking by the accused even after the aggressor had been neutralized, is especially instructive: The act of appellant in repeatedly hacking Norman on his head and neck was not a reasonable and necessary means of repelling the aggression allegedly initiated by the latter. As stated earlier, no convincing evidence was presented to show that Norman was armed with an ice-pick at the time of the incident. In fact, no ice-pick was found in the crime scene or in the body of the victim. There was also no proof showing that Norman attempted to stab appellant or tried to barge into the latter's house. Granting arguendo that Norman was armed with an ice-pick, the repeated hackings were not necessary since he can overpower or disable Norman by a single blow on non-vital portion/s of his body.
	GR No. 186538 2009-11-25	PEOPLE v. AUSENCIO COMILLO CHICO-NAZARIO, J.
Likewise, appellants are not entitled to the mitigating circumstance of sufficient provocation or threat on the part of the offended party, which must have immediately preceded the crime as provided in Article 13(4) of the Revised Penal Code. Before the same can be appreciated, the following elements must concur: (1) that the provocation or threat must be sufficient or proportionate to the crime committed and adequate to arouse one to its commission; (2) that the provocation or threat must originate from the offended party; and (3) that the provocation must be immediate to the commission of the crime by the person provoked.[60]
	GR No. 186119 2009-10-27	PEOPLE v. PABLO LUSABIO CHICO-NAZARIO, J.
We now go to the award of damages. When death occurs due to a crime, the following damages may be awarded: (1) civil indemnity ex delicto for the death of the victim; (2) actual or compensatory damages; (3) moral damages; (4) exemplary damages; and (5) temperate damages.[51]
	GR No. 185841 2009-08-04	PEOPLE v. ISMAEL DIAZ CHICO-NAZARIO, J.
We now go to the award of damages. When death occurs due to a crime, the following damages may be awarded: (1) civil indemnity ex delicto for the death of the victim; (2) actual or compensatory damages; (3) moral damages; (4) exemplary damages; and (5) temperate damages.[66]
	GR No. 185162 2009-04-24	PEOPLE v. ROLLY GIDOC CHICO-NAZARIO, J.
When death occurs due to a crime, the following damages may be awarded: (1) civil indemnity ex delicto for the death of the victim; (2) actual or compensatory damages; (3) moral damages; (4) exemplary damages; and (5) temperate damages.[25]
	GR No. 173791 2009-04-07	PEOPLE v. PABLO AMODIA BRION, J.
[115] People v. Beltran, Jr., G.R. No. 168051, September 27, 2006, 503 SCRA 715, 740-741; People v. Malinao, G.R. No. 128148, February 16, 2004, 423 SCRA 34, 55; People v. Caloza, Jr., G.R. Nos. 138404-06, January 28, 2003, 396 SCRA 329, 346-347; People v. Rafael, G.R. Nos. 146235-36, May 29, 2002, 382 SCRA 753, 770-771.
	GR No. 184173 2009-03-13	PEOPLE v. JUDITO MOLINA CHICO-NAZARIO, J.
As to damages. When death occurs due to a crime, the following damages may be awarded: (1) civil indemnity ex delicto for the death of the victim; (2) actual or compensatory damages; (3) moral damages; (4) exemplary damages; and (5) temperate damages.[54]
	GR No. 184343 2009-03-02	PEOPLE v. JESUS DOMINGO CHICO-NAZARIO, J.
When death occurs due to a crime, the following damages may be awarded: (1) civil indemnity ex delicto for the death of the victim; (2) actual or compensatory damages; (3) moral damages; (4) exemplary damages; and (5) temperate damages.[32]
	GR Nos. 119660-61 2009-02-13	PAT. EDGARDO HERRERA Y BALTORIBIO v. SANDIGANBAYAN AZCUNA, J.
Eighth. Public respondent Sandiganbayan did not grant any award of damages in favor of the heirs of Shi Shu Yang and George Go y Tan. When death occurs due to a crime, the following damages may be awarded: (1) civil indemnity ex delicto for the death of the victim; (2) actual or compensatory damages; (3) moral damages; (4) exemplary damages; and (5) temperate damages.[34]
	GR No. 176609 2008-12-18	FERNANDO ESTABAS MAHAWAN v. PEOPLE CHICO-NAZARIO, J.
The fact that petitioner sustained injuries on his hand and stomach, allegedly caused by Paradero's knife, does not signify that he was a victim of unlawful aggression. The medical certificate presented by petitioner states that the latter sustained incised wounds on the 2nd and 5th fingers measuring 2 centimeters and abdominal abrasion measuring 2.5 centimeters. Petitioner was discharged on the same day he was treated in the hospital.[29] It is clear from the foregoing that the injuries he sustained were not serious or severe. The superficiality of the injuries was not indication that his life and limb were in actual peril.[30]
	GR No. 181631 2008-09-30	PEOPLE v. JOSE BALINAS TINGA, J.
It is doctrinal that when the credibility of a witness is in issue, the findings of fact of the trial court, its calibration of the testimonies of the witnesses and its assessment of the probative weight thereof, as well as its conclusions anchored on said findings are accorded high respect if not conclusive effect. This is because the trial court has the unique opportunity to observe the demeanor of a witness and is in the best position to discern whether he is telling the truth. It is likewise settled that when the trial court's findings have been affirmed by the appellate court, said findings are generally conclusive and binding upon this Court.[19]
	GR No. 181632 2008-09-25	PEOPLE v. JESSIE BALLESTA CHICO-NAZARIO, J.
We now go to the award of damages. When death occurs due to a crime, the following damages may be awarded: (1) civil indemnity ex delicto for the death of the victim; (2) actual or compensatory damages; (3) moral damages; (4) exemplary damages; and (5) temperate damages.[47]
	GR No. 173824 2008-08-28	PETER TARAPEN Y CHONGOY v. PEOPLE CHICO-NAZARIO, J.
Third. Lack of sufficient provocation on the part of the person defending himself. Having admitted that he killed James, the burden of evidence that one acted in self-defense shifted to petitioner. Like an alibi, self-defense is inherently weak, for it is easy to fabricate.[61] It is textbook doctrine that when self-defense is invoked, the burden of evidence shifts to the accused to show that the killing was justified, and that he incurred no criminal liability therefor. He must rely on the strength of his own evidence and not on the weakness of the prosecution's evidence, for, even if the latter were weak, it could not be disbelieved after his open admission of responsibility for the killing. Hence, he must prove the essential requisites of self-defense as aforementioned.[62]
	GR No. 178540 2008-06-27	PEOPLE v. ALEJANDRO SORILA YNARES-SATIAGO, J.
The testimony of a single eyewitness, if found to be positive and credible by the trial court, is sufficient to support a conviction,[43] especially when it bears the earmarks of truth and sincerity and was delivered spontaneously, naturally and in a straightforward manner.[44] Indeed, the testimony of a single witness when found sufficient needs no corroboration, save only where the law expressly prescribes a minimum number of witnesses. [45] Errorless testimonies can hardly be expected especially when a witness is recounting the details of a harrowing experience. As long as the mass of testimony jibes on material points, the slight clashing of statements dilute neither the witnesses' credibility nor the veracity of their testimonies. Such inconsistencies on minor details would even enhance credibility as these discrepancies indicate that the responses are honest and unrehearsed."[46] The Court has consistently ruled that the alleged inconsistencies between the testimony of a witness in open court and his sworn statement before the investigators are not fatal defects to justify the reversal of a judgment of conviction.[47]
	GR No. 178546 2008-04-30	PEOPLE v. MUKIM ELING Y MAÑALAC CHICO-NAZARIO, J.
We retain the award of exemplary damages but reduced the amount to P25,000.00 following current jurisprudence.[51] Exemplary damages in the amount of P25,000.00 must be awarded, given the presence of treachery which qualified the killing to murder. Article 2230 of the Civil Code allows the award of exemplary damages as part of the civil liability when the crime was committed with one or more aggravating circumstances. The term aggravating circumstance as used therein should be construed in its generic sense since it did not specify otherwise.
	GR No. 173282 2008-03-04	JOSE INGAL y SANTOS v. PEOPLE CHICO-NAZARIO, J.
With respect to award of damages, both the trial court and the Court of Appeals did not award any. When death occurs due to a crime, the following damages may be awarded: (1) civil indemnity ex delicto for the death of the victim; (2) actual or compensatory damages; (3) moral damages; (4) exemplary damages; and (5) temperate damages.[64]
	GR No. 175326 2007-11-28	PEOPLE v. EDGARDO SANTIAGO Y GATDULA CHICO-NAZARIO, J.
Although it is true that the foregoing inconsistencies refer to the situations during the buy-bust itself, these cannot destroy the positive and credible testimony of Inspector Cortez that he handed over to Vladimir the briefcase with boodle money in exchange for 312.2 grams of shabu. Further, we have consistently ruled that the alleged inconsistencies between the testimony of a witness in open court and his sworn statement are not fatal defects to justify a reversal of judgment of conviction. Such discrepancies do not necessarily discredit the witness since ex-parte affidavits are almost always incomplete. Sworn statements taken ex-parte are generally considered to be inferior to the testimony given in open court.[50]
	GR No. 175594 2007-09-28	PEOPLE v. JUNJUN DUCABO CHICO-NAZARIO, J.
We now go to the award of damages. When death occurs due to a crime, the following damages may be awarded: (1) civil indemnity ex delicto for the death of the victim; (2) actual or compensatory damages; (3) moral damages; (4) exemplary damages; and (5) temperate damages.[34]
	GR NO. 175881 2007-08-28	PEOPLE v. ARMANDO RODAS CHICO-NAZARIO, J.
We now go to the award of damages. When death occurs due to a crime, the following damages may be awarded: (1) civil indemnity ex delicto for the death of the victim; (2) actual or compensatory damages; (3) moral damages; (4) exemplary damages; and (5) temperate damages.[56]
	GR NO. 172184 2007-07-10	NESTOR B. DECASA v. CA CHICO-NAZARIO, J.
More importantly, this Court had consistently ruled that the alleged inconsistencies between the testimony of a witness in open court and his sworn statement before the investigators are not fatal defects to justify a reversal of judgment. Such discrepancies do not necessarily discredit the witness since ex-parte affidavits are almost always incomplete. A sworn statement or an affidavit does purport to contain a complete compendium of the details of the event narrated by the affiant. Sworn statements taken ex parte are generally considered to be inferior to the testimony given in open court.[21]
	GR NO. 170298 2007-06-26	MANUEL S. ISIP v. PEOPLE CHICO-NAZARIO, J.
It is axiomatic that when it comes to credibility, the trial court's assessment deserves great weight, and is even conclusive and binding, if not tainted with arbitrariness or oversight of some fact or circumstance of weight and influence. The reason is obvious. Having the full opportunity to observe directly the witnesses' deportment and manner of testifying, the trial court is in a better position than the appellate court to evaluate properly testimonial evidence.[19] It is to be pointed out that the findings of fact of the trial court have been affirmed by the Court of Appeals. It is settled that when the trial court's findings have been affirmed by the appellate court, said findings are generally conclusive and binding upon this Court.[20] In the case at bar, we find no compelling reason to reverse the findings of the trial court, as affirmed by the Court of Appeals, and to apply the exception. We so hold that there is sufficient evidence to show that the particular transaction took place in Cavite City.