GR 120367; (October, 2000) (Digest)
G.R. No. 120367 ; October 16, 2000
People of the Philippines vs. Antonio Barreta, Danilo Barreta, Lito Barreta, Domingo Barreta (At Large), Edgar Barreta, and Rogelio Barreta
FACTS
On January 26, 1988, in a remote area of Babatngon, Leyte, the brothers Antonio, Danilo, Domingo, Edgar, Lito, and Rogelio, all surnamed Barreta, attacked the house of Clemente Tesaluna, Sr. The prosecution’s eyewitness, Dominador Balboa, testified that he saw Antonio, Lito, and Danilo simultaneously stab the unarmed victim with bolos while the other brothers, Domingo, Edgar, and Rogelio, ransacked the house. The assailants then fled, taking with them cash and farm implements. Clemente died from multiple stab and hacking wounds. Only four accused—Antonio, Edgar, Lito, and Rogelio—were apprehended and jointly tried for Murder and Robbery in Band.
The defense presented a contradictory version, claiming that only Lito Barreta was responsible for the killing. They alleged that Lito acted in self-defense after being accosted and attacked by Clemente, who suspected him of stealing tuba. The defense denied any conspiracy to commit robbery, asserting the other brothers were not present at the scene.
ISSUE
The core issue is whether the prosecution proved beyond reasonable doubt the guilt of the accused-appellants for the complex crimes of Murder and Robbery in Band.
RULING
The Supreme Court affirmed the convictions. The Court found the testimony of eyewitness Dominador Balboa credible, consistent, and sufficient to establish the events. His positive identification of all six brothers, whom he knew from a neighboring barangay, overcame the defenses of denial and alibi. The simultaneous stabbing by three brothers demonstrated a concerted effort to kill, proving conspiracy in the murder. The act of ransacking the house and taking property concurrently with the attack established a common purpose to commit robbery.
The claim of self-defense by Lito Barreta failed because the nature, number, and location of the victim’s wounds, coupled with the aggressive actions of multiple attackers, were incompatible with a theory of unlawful aggression by a solitary victim. The Court upheld the qualifying circumstance of abuse of superior strength for the Murder charge, given the six armed brothers attacking one unarmed man. For Robbery in Band, the element of more than three armed malefactors was satisfied. The penalties imposed by the trial court were affirmed as within the legal bounds prescribed for the crimes.