GR 113940; (February, 2000) (Digest)
G.R. No. 113940 February 15, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CIELITO BULURAN y RAMIREZ and LEONARDO VALENZUELA y CASTILLO, accused-appellants.
FACTS
On May 16, 1993, during a family gathering in Novaliches, Quezon City, an altercation occurred between the victim, Edilberto Meyer, Sr., and Reynaldo Danao. After an initial fistfight, Danao left but returned minutes later with three companions: appellants Cielito Buluran and Leonardo Valenzuela, and Jaime Danao. Reynaldo Danao, armed with a knife, stabbed the victim in the back. Appellants, armed with a knife and a loaded slingshot respectively, stood guard and pointed their weapons at the victim’s relatives and bystanders to prevent any intervention or aid. The group then fled, and the victim died that night.
At trial, the prosecution presented eyewitnesses who consistently identified appellants as part of the armed group that facilitated the killing. The defense presented alibi, claiming appellants were asleep at home, and an alternative narrative where the victim and others allegedly stabbed Reynaldo Danao first. The trial court convicted appellants of murder, finding conspiracy and treachery.
ISSUE
Whether the accused-appellants are guilty of the crime of murder.
RULING
Yes, the Supreme Court affirmed the conviction for murder. The Court found the testimonies of the prosecution eyewitnesses credible, consistent, and positive in identifying appellants’ participation. Their collective actions—arriving together armed, with Buluran and Valenzuela actively preventing help from reaching the victim by brandishing their weapons—conclusively established conspiracy. By mutual design, they rendered the victim defenseless, ensuring the success of the fatal attack without risk to themselves. This concerted effort constituted treachery, qualifying the killing to murder.
The defense of alibi was correctly rejected for being weak and unsubstantiated, especially in light of the positive identification by credible witnesses. The alternative story presented by the defense, including evidence that Reynaldo Danao was later treated for wounds, was deemed irrelevant to appellants’ criminal liability, as it did not disprove their direct participation in the victim’s killing. The Court modified the damages awarded but upheld the penalty of reclusion perpetua, as the prosecution proved appellants’ guilt as co-conspirators beyond reasonable doubt.