GR 126283; (May, 1999) (Digest)
G.R. No. 126283 May 28, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RUBEN ESTEPANO, RODNEY ESTEPANO and RENE ESTEPANO, accused-appellants.
FACTS
Enrique Balinas was stabbed and hacked to death. Accused-appellants Ruben, Rodney, and Rene Estepano, along with others, were charged with murder. The prosecution’s case primarily relied on the eyewitness account of Florencio Tayco. He testified that on the evening of April 16, 1991, while walking home with the victim and another companion, they encountered Dominador Estepano. Suddenly, Rodrigo Estepano appeared and stabbed Balinas. Florencio positively identified Ruben, Rodney, Rene, and another as having followed suit in hacking the fallen victim, with Dominador egging them on. The defense presented alibis and a conflicting version from another eyewitness, Lopito Gaudia, who stated he only saw Rodrigo and one other assailant.
ISSUE
The core issues were: (1) the credibility of the prosecution eyewitness; (2) the existence of conspiracy among the accused; and (3) the correctness of the murder conviction.
RULING
The Supreme Court affirmed the convictions of Ruben and Rodney Estepano but acquitted Rene. On credibility, the Court upheld the trial court’s assessment, giving full faith to Florencio Tayco’s clear, positive, and convincing testimony, which was corroborated by medical findings of multiple wounds indicative of several assailants. The minor inconsistencies with Lopito Gaudia’s testimony did not destroy Florencio’s credibility. On conspiracy, the Court found it sufficiently established by the appellants’ collective and simultaneous attack on the defenseless victim, demonstrating a community of criminal purpose. The killing was qualified by treachery, as the attack was sudden and unexpected, rendering the victim unable to defend himself. However, for Rene Estepano, who was thirteen years old at the time of the crime, the Court ruled that the prosecution failed to prove he acted with discernment, a requisite for juvenile criminal liability. Thus, he was acquitted. The Court modified the damages awarded, including compensation for loss of earning capacity.