G.R. No. 116098 . April 26, 1996.
GEORGE C. ARCENO, SAMSON C. ARCENO, ZALDY C. ARCENO, ROBERTO P. JINO-O, MARCELINO S. PALMA, JR. and NOEL A. BANICO, petitioners, vs. PEOPLE OF THE PHILIPPINES and THE HONORABLE SANDIGANBAYAN, respondents.

FACTS

Petitioners, members of the Integrated National Police and the Philippine Constabulary, were convicted by the Sandiganbayan of Murder for the killing of Bernardito P. Vencer on April 25, 1986, in Batad, Iloilo. The prosecution established that a group including the petitioners, while allegedly on a military operation to arrest Vencer, took him from his uncle’s house without a warrant. Eyewitness Edmundo Evangelio, hiding nearby, testified that he saw the petitioners bring Vencer to a hut, interrogate him, and then shoot him. The victim’s uncle, Bernardino Vencer, and another witness, Fernando Aguasa, corroborated the events leading to the abduction, identifying several petitioners as part of the armed group that took Vencer. Shortly after the group left with Vencer, successive gunshots were heard.
The defense generally interposed alibi, claiming they were elsewhere during the incident. The Sandiganbayan found the prosecution witnesses credible, noting the bright moonlight enabled clear identification, and rejected the alibi defenses for lack of credibility and the non-impossibility of the accused being at the crime scene. The court found the killing was qualified by abuse of superior strength.

ISSUE

Whether the Sandiganbayan erred in convicting the petitioners of Murder based on the evidence presented.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that factual findings of the trial court, including the Sandiganbayan, on witness credibility are accorded great weight and respect, as it is in a better position to assess testimonial evidence. The positive identification of the petitioners by multiple eyewitnesses, under conditions of sufficient moonlight, prevailed over their weak and uncorroborated alibis. The Court upheld the finding of conspiracy, which can be inferred from the collective and coordinated actions of the accused before, during, and after the crime—arriving as an armed group, jointly abducting the victim, and collectively participating in the killing. Conspiracy having been established, the act of one is the act of all. The qualifying circumstance of abuse of superior strength was correctly appreciated due to the overwhelming number of armed assailants against a single, unarmed victim. The Court found no reversible error in the Sandiganbayan’s judgment, which was supported by the evidence on record proving guilt beyond reasonable doubt.