G.R. No. L-39144. July 30, 1979.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REYNALDO AREVALO, BERNARDO AREVALO, ERNITO AREVALO, and ROCEVAL AREVALO, accused-appellants.

FACTS

The four appellants were convicted of murder for the killing of Abelardo Gonzales on March 3, 1971, in Pilar, Capiz. The prosecution’s evidence, primarily from the victim’s son, Chito Gonzales, and eyewitness Juanito Benjamin, established that while the victim was walking home with his two young sons, he was suddenly attacked from behind by Reynaldo Arevalo with a bolo. The other appellants, Bernardo, Ernito, and Roceval Arevalo, then joined in, collectively assaulting the fallen victim with their weapons. The autopsy revealed multiple severe incised wounds, causing death from severe hemorrhage.
The defense presented contradictory accounts. Accused Reynaldo Arevalo admitted to inflicting the fatal injuries but claimed he acted alone in self-defense, alleging the victim had first attacked him. The other three accused interposed the defense of alibi, denying their presence at the crime scene. The trial court rejected these defenses, finding the prosecution witnesses credible and their testimonies consistent with the physical evidence, and convicted all four as principals of murder qualified by treachery.

ISSUE

The core issue is whether the trial court erred in convicting all four appellants of murder, specifically in rejecting Reynaldo Arevalo’s claim of self-defense and the alibis of the other accused, and in finding the qualifying circumstance of treachery.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the evaluation of evidence and the elements of the crime. For self-defense, the burden of proof shifts to the accused, who must prove unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. Reynaldo Arevalo’s claim failed as the number, nature, and location of the victim’s wounds—multiple deep hacking wounds on the back and neck—were inconsistent with a sudden defensive act and instead indicated a determined assault. The Court found his version inherently improbable and upheld the trial court’s assessment of the prosecution witnesses as more credible.
Regarding the other appellants, the defense of alibi is inherently weak and cannot prevail over the positive identification by credible eyewitnesses who had no motive to falsely testify. The Court also addressed the minor inconsistency concerning Roceval’s identification, noting it was logical that Chito Gonzales did not see Roceval’s specific acts as he had already fled the scene with his younger brother. The collective action of the four armed men in suddenly attacking the victim from behind established the qualifying circumstance of treachery (alevosia), as the mode of attack ensured the victim’s defenselessness. This circumstance absorbed the alleged aggravating circumstances of nighttime and superior strength. With no other modifying circumstances, the penalty of reclusion perpetua was correctly imposed.