G.R. No. L-37945 May 28, 1984
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ADRIANO CAÑETE and JOSE BILOG alias BOY, defendants-appellants.

FACTS

Accused Jose Bilog and the victim, Douglas Bilog, were brothers with a history of conflict over inherited land. In April 1971, Jose attempted to waylay Douglas with a shotgun but was intercepted. He later offered prisoner Nicasio Dayao P300 to kill Douglas, which Dayao refused. On April 19, 1972, eyewitness Antonio Cabig, an inmate, saw Jose and Douglas drinking in Jose’s hut. Appellant Adriano Cañete and two others joined them. After the group became drunk, Jose suddenly stabbed Douglas with a bladed weapon. Cañete then took the same weapon and also stabbed the victim. The two other companions assisted by hitting Douglas with a piece of wood until he died. The body, bearing 26 wounds, was dumped in a canal.
Post-crime, Cañete changed out of his bloodied clothes at a fellow inmate’s hut. He was later taken into custody, where he voluntarily confessed and led police to the murder weapon. Jose Bilog presented an alibi, claiming he was at home while his wife was marketing. The trial court convicted both accused of murder and sentenced them to death.

ISSUE

Whether the guilt of appellants Adriano Cañete and Jose Bilog for the crime of murder was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua due to lack of necessary votes for the death penalty. The positive and credible eyewitness account of Antonio Cabig, who had no motive to falsely testify, directly established the appellants’ participation in the killing. His testimony detailed the sudden attack by Jose Bilog and the subsequent stabbing by Cañete, which was consistent with the autopsy findings of multiple wounds.
The Court rejected Jose Bilog’s alibi as inherently weak. The distance between his home and the crime scene was merely three kilometers, which did not preclude his presence at the hut, a fact corroborated by other witnesses who saw him traveling there. Cañete’s extrajudicial confession, given voluntarily and corroborated by his surrender of the weapon, was deemed credible. His attempt to repudiate it was unconvincing, as his own testimony revealed a prior discussion of a monetary consideration for the killing.
The crime was qualified by treachery (alevosia), as the attack was sudden and unexpected, depriving the victim of any chance to defend himself despite a prior altercation. The aggravating circumstance of price or reward was also present, affecting both giver and receiver, based on Jose’s earlier offer to Dayao. The Court upheld the trial court’s factual findings and assessment of witness credibility, leading to the affirmance of the judgment with the modified penalty.