GR 116486; (January, 1996) (Digest)
G.R. No. 116486 ; January 29, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODRIGO MALIPUT y REYES, UNDO DAPROSA y WATIG alias ALEXANDER JUMAWAN, and JOHN DOE, accused-appellants.
FACTS
On the night of April 7, 1991, spouses Chua Chun and Ho Tin, owners of Popong’s Grocery in San Fernando, Pampanga, were found brutally murdered inside their store. Ho Tin was found hogtied with a sack over her head, while Chua Chun was discovered in a bathroom with his throat slashed. Their son, Tony Choi, testified that while searching for his parents, he saw three men—identified as former employee Jun-Jun Reyes and current employees Rodrigo Maliput and Undo Daprosa (alias Alexander Jumawan)—fleeing from the scene. Police investigation recovered bloodstained weapons, including an improvised ice pick and broken glass.
A police manhunt led to the apprehension of Maliput and Daprosa at a nearby road junction. Daprosa attempted to flee but was captured after a brief chase. Both were charged with double murder. The third suspect, Jun-Jun Reyes, remained at large. The prosecution’s case hinged on Tony Choi’s eyewitness identification and circumstantial evidence, including the accused’s flight and absence during the employee line-up conducted after the crime.
ISSUE
The core issue is whether the guilt of accused-appellants Rodrigo Maliput and Undo Daprosa for the crime of double murder was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction, finding the totality of circumstantial evidence sufficient to establish guilt beyond reasonable doubt. The Court meticulously applied the rules on circumstantial evidence, requiring that: (a) there is more than one circumstance; (b) the facts from which the inferences are derived are proven; and (c) the combination of all circumstances produces a conviction beyond moral certainty of the accused’s guilt. The chain of circumstances was unbroken: the accused were positively identified fleeing the crime scene; they were absent when police summoned all employees; they were apprehended while hiding and attempting to flee; and no plausible reason was given for their suspicious conduct and flight, which indicated guilt. The Court rejected the defense of frame-up and alibi as weak and unsubstantiated.
The qualifying circumstance of abuse of superior strength was correctly appreciated, as the elderly and unarmed victims were overpowered and mercilessly killed. The Court modified the penalty to reclusion perpetua for each count of murder and ordered the accused to pay civil indemnity of P50,000 to the heirs of each victim. The decision underscores that conspiracy can be inferred from the collective acts of the accused before, during, and after the crime, and that flight is a strong indication of guilt.