G.R. No. L-71142 September 19, 1988
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LOPE MARALIT and ROMY PASIA, accused-appellants.

FACTS

Accused-appellants Lope Maralit and Romy Pasia, along with Pedro Pacheca and Manang Mendoza, were charged with the murder of Jaime Cordelin on October 2, 1982, in Carmona, Cavite. The prosecution, through the victim’s sons Bienvenido and Danilo Cordelin, established that the assailants, positioned on an elevated roadside, fired upon the victim and his sons as they walked to their farm. The victim, shot multiple times from behind, died at the scene. Empty shells from an M-16 rifle and a .45 caliber pistol were recovered. The motive was rooted in a land dispute between the victim and the International Realty Corporation, where Maralit worked as foreman and Pacheca as overseer. Prior threats and the burning of the victim’s huts by the accused group were documented.
The defense relied on denial and alibi. Maralit and Pasia claimed they were at their workplace preparing and signing an attendance report at the exact time of the shooting, a claim corroborated by the plantation manager, Generoso Panopio, and others. The trial court acquitted Pasia on reasonable doubt but convicted Maralit of murder qualified by treachery, sentencing him to reclusion perpetua. The court found conspiracy among Maralit, Pacheca, and Mendoza based on the sequence of events.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that accused-appellant Lope Maralit conspired in the murder of Jaime Cordelin.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the establishment of conspiracy through circumstantial evidence and the weakness of the defense’s alibi. Conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. Direct proof is not essential; it may be inferred from the conduct of the accused before, during, and after the crime, indicating a common design.
The Court found conspiracy convincingly demonstrated. Maralit, as foreman, had a clear motive linked to the corporate land dispute. His presence with the armed assailants at the crime scene, as positively identified by two eyewitnesses, was not passive. The act of firing from an elevated position at the unsuspecting victim from behind constituted treachery, qualifying the killing to murder. The collective execution of the attack, following prior threats and hostile acts like the burning of huts, evidenced a concerted effort to eliminate the victim.
The defense of alibi was properly rejected. For alibi to prevail, the accused must prove not only their presence elsewhere but also the physical impossibility of being at the crime scene. The workplace was not so distant as to preclude Maralit’s presence at the locus criminis. The corroborating testimonies from interested witnesses, including relatives, lacked credibility. The positive identification by the eyewitnesses, who had no ill motive to testify falsely, prevailed over the weak alibi. Thus, Maralit’s criminal liability as a co-conspirator was established beyond reasonable doubt.