G.R. No. L-56113. January 31, 1984.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JAIME VILLEZA, ANTONIO VILLEZA, ROBERTO ALA, JR., and ANTONIO GANADEN, defendants-appellants.

FACTS

The four accused were charged with Murder for the fatal stabbing of Bonifacio Turla on February 4, 1978, in Manila. The prosecution’s case primarily rested on the eyewitness account of Fernando Enguerra, a 14-year-old balut vendor. He testified that while buying a drink at a store, he saw the four accused, who were his neighbors, seated nearby. He witnessed Antonio Ganaden, Roberto Ala, Jr., and Antonio Villeza boxing the victim, causing him to fall. He then heard one of them urge, “Sige na, tirahan mo na para hindi na siya makapunta sa pulis!” Jaime Villeza then stabbed the supine victim multiple times with a knife. All accused fled, and the victim later died from six penetrating stab wounds.
The defense consisted of alibi and denial. Antonio Villeza claimed he was at a distant construction site. Antonio Ganaden and Roberto Ala, Jr., while placing themselves near the scene, denied stabbing the victim. Jaime Villeza initially presented himself as a witness but later gave conflicting statements, eventually admitting to stabbing the victim twice after being told to do so by a co-accused. All accused were convicted of Murder by the Circuit Criminal Court, prompting this appeal.

ISSUE

The core issue is whether the guilt of all accused for the crime of Murder was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the convictions. The positive identification by eyewitness Fernando Enguerra was deemed credible and sufficient to establish guilt. The Court found no reason to doubt his testimony, noting he had no motive to falsely accuse the appellants, who were his neighbors. His account was clear, consistent, and corroborated by the physical evidence and the accused’s own extrajudicial statements. The defense of alibi was rejected as it could not overcome the positive identification, and the claimed distances did not constitute physical impossibility for the accused to be at the crime scene.
The legal logic for finding Murder qualified by treachery is sound. The attack was sudden, with the victim being boxed and rendered defenseless on the ground before being repeatedly stabbed. This method of execution ensured the victim had no opportunity for self-defense, satisfying the criterion of treachery. The Court also upheld the trial court’s appreciation of voluntary surrender as a mitigating circumstance for three appellants, but not for Jaime Villeza, who only approached the police under the guise of being a witness. The indemnity was increased to P30,000.00. The collective actions, from the boxing to the stabbing, established conspiracy, making all participants equally liable for the resulting death.