G.R. No. L-49856; April 3, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VICTOR BAYBAYON and DOMINGO ATIBAGOS, accused-appellants.

FACTS

Accused-appellants Victor Baybayon and Domingo Atibagos were convicted of murder for the killing of Romulo Baterna. The prosecution evidence established that on the evening of May 15, 1971, Baybayon and Atibagos were drinking at a sari-sari store. When Baterna and his companion Jesus Raymundo arrived, Baybayon offered them a drink. Upon Baterna’s refusal, Baybayon poured liquor on their faces. When Baterna protested, Baybayon drew a fan knife. Baterna and Raymundo fled, pursued by the appellants. Baterna slipped and fell, whereupon Baybayon stabbed him. Baterna rose and ran but was overtaken and stabbed again. Atibagos then delivered a fist blow to the back of Baterna’s neck before both assailants fled. The victim died from severe hemorrhage secondary to a stab wound.
The defense did not present evidence, instead challenging the credibility of prosecution witnesses Julian Ronsairo and Jesus Raymundo by pointing to alleged inconsistencies. The trial court found the eyewitness accounts credible and convicted both appellants, sentencing them to life imprisonment. The case was elevated directly to the Supreme Court due to the penalty imposed.

ISSUE

The core issues were: (1) whether the corpus delicti was proven as to Baybayon given the timing of the medico-legal testimony, and (2) whether the evidence sufficiently established conspiracy and the qualifying circumstance of treachery.

RULING

The Supreme Court affirmed the conviction. On the first issue, the Court held that proof of the corpus delicti—the fact of death and its criminal agency—does not depend solely on expert testimony. Lay testimony is equally admissible. Here, eyewitnesses Ronsairo and Raymundo positively testified to the fatal stabbing, and Baybayon’s argument was deemed untenable as he did not even dispute that Baterna was killed.
On the second issue, the Court found conspiracy duly established. Both appellants pursued the victim together. Baybayon inflicted the fatal wounds while Atibagos, by chasing Baterna and striking him while he was down, demonstrated a community of criminal design. Under the principle that the act of one conspirator is the act of all, Atibagos is equally liable for the murder. Treachery (alevosia) was present because the attack was continuous and the victim, having fallen, was in no position to defend himself, ensuring the execution of the crime without risk to the assailants. The minor inconsistencies in the witnesses’ accounts did not impair their credibility but rather indicated unrehearsed testimony. The Court modified the award of civil indemnity from P12,000 to P30,000 but affirmed the penalty of life imprisonment.