People of the Philippines vs. Tirso Sibbu G.R. No.

214757 – March 29, 2017

Criminal Law
Topic: Attempted Murder/Night Time/ Qualifying Circumstance of Treachery/ Aggravating
Circumstances of dwelling and disguise
Facts: Accused-appellant is found guilty for the crime of Attempted Murder against private
complainant Bryan Julian. The former was identified by the latter by means of the Christmas
lights sufficiently illuminating and identifying the assailant shooting at him and his family. The
alibi of the defence stated that accused-appellant was not present as he was at his in-laws
house caring for his sick child. The same was stated by his father and mother in law.
Issue: WON the courts have erred in finding the accused-appellant guilty beyond reasonable
doubt.
Held: RTC rendered judgement finding appellant guilty beyond reasonable doubt, defense and
alibi weak. CA affirmed RTCs decision. xxx No. The SC finds the appeal unmeritorious. The
findings of the RTC, which were affirmed by the CA, that Bryan positively identified appellant as
the person who shot at him and killed Warlito, Ofelia, and Trisha. We have consistently ruled
that factual findings of trial comts, especially when affirmed by the appellate court, are entitled to
respect and generally should not be disturbed on appeal unless certain substantial facts were
overlooked which, if considered, may affect the outcome of the case. After due consideration of
the records of the case and the evidence adduced, the Court finds that the RTC and the CA did
not err in their appreciation of the facts and evidence.