G.R. Nos. 80110-11 March 22, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANILO DUMPE y JIMENEZ, DANILO CLEMENTE y MANALO, JEREMIAS SEBASTIAN y BASA, defendants-appellants.

FACTS

On May 15, 1982, around 1:30 AM, Guillermo Ocampo and Joselito Dungca were accosted in Caloocan City by two individuals, “Amboy” and “Boboy Laki.” Upon discovering Ocampo had a tattoo, they were brought to a group, including appellants Dumpe, Clemente, and Sebastian, who were drinking nearby. The group was told Ocampo was a “spy,” prompting them to maul him. The assault escalated, involving boxing, cutting his hair with a balisong, and slashing his tattoo mark. Appellant Clemente later participated in a contest to knock Ocampo down with one punch. Subsequently, appellants Dumpe and Sebastian took Ocampo to a nearby cemetery while Dungca, Clemente, and others remained at a basketball court.
Dungca later saw Dumpe and Sebastian return to the basketball court running, with bloodied clothes and one holding a bloodied knife. When Clemente asked what happened, they replied, “ayos na” (it is already done). That same morning, Ocampo’s body was found in the cemetery with 22 stab wounds. All three appellants denied involvement, presenting alibis that they were elsewhere during the incident, either at home, work, or a dance hall.

ISSUE

Whether the trial court erred in convicting the appellants of murder based on the testimony of a single eyewitness and circumstantial evidence.

RULING

The Supreme Court affirmed the conviction. The testimony of prosecution witness Joselito Dungca was deemed credible and sufficient to establish guilt beyond reasonable doubt. The Court emphasized that the trial court’s assessment of witness credibility is accorded great respect, as it is in the best position to observe demeanor. While Dungca did not witness the actual stabbing in the cemetery, the chain of circumstantial evidence was compelling: the initial mauling over the tattoo, the violent acts including hair-cutting and tattoo-slashing, the contest involving Clemente, the act of Dumpe and Sebastian taking the victim to the cemetery, and their immediate return with bloodied clothes and a weapon while declaring the deed “done.” This sequence of events conclusively pointed to the appellants’ collective responsibility for Ocampo’s killing.
The Court found conspiracy among the appellants. Although Clemente did not go to the cemetery, his active participation in the earlier mauling and his presence during the critical events before and after the killing demonstrated a unity of purpose and intent with his co-appellants. Their alibis were correctly rejected for being weak and unpersuasive, especially given the accessibility of their claimed locations to the crime scene. The crime was properly qualified as murder due to abuse of superior strength, as the appellants, armed and in a group, used excessive force against an unarmed and outnumbered victim. The penalty of reclusion perpetua was sustained, with only the damages award modified to P30,000.00.