G.R. No. 125894 December 11, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NARITO ARANETA, accused-appellant.

FACTS

Accused-appellant Narito Araneta, along with four others, was charged with Murder and Frustrated Murder for the death of Mansueto Datoon, Jr. and the wounding of Hilario Malones on December 6, 1989, in Anilao, Iloilo. The prosecution presented eyewitnesses Hilario Malones and his wife, Fe. They testified that around 8:30 p.m., they heard a commotion and saw Narito and his co-accused beating Mansueto. When Hilario intervened, Joebert Araneta shot him. Joebert then shot Mansueto at close range, after which Narito and the others resumed beating the victim. Medical evidence confirmed Mansueto died from multiple gunshot wounds and severe physical injuries, while Hilario survived due to timely medical intervention.
Narito Araneta interposed the defense of alibi, claiming he was at home asleep during the incident. He was corroborated by his wife, Candelaria, and a visitor, Nelson Salo, who testified that Narito never left the house that evening. The trial court convicted Narito of Murder, sentencing him to reclusion perpetua, and acquitted him of Frustrated Murder. He appealed, arguing the prosecution failed to prove his guilt beyond reasonable doubt and that his alibi should prevail over the positive identification by witnesses.

ISSUE

Whether the prosecution proved the guilt of accused-appellant Narito Araneta for the crime of Murder beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the positive identification by eyewitnesses Hilario and Fe Malones to be credible, consistent, and categorical. They clearly saw Narito actively participating in beating Mansueto Datoon, Jr. under sufficient illumination from a nearby fluorescent lamp. The defense of alibi, requiring proof of physical impossibility to be at the crime scene, failed as the Araneta residence was merely 150 meters away, making his presence at the locus criminis entirely possible. The testimonies of the defense witnesses, being relatives and a friend, were deemed inherently biased and insufficient to overcome the positive identification.
The Court ruled that conspiracy was established. Narito’s acts of beating the victim before and after the fatal shooting, in concert with his co-accused, demonstrated a community of criminal purpose. In conspiracy, the act of one is the act of all; thus, Narito is equally liable for the killing perpetrated by Joebert. The crime was Murder qualified by abuse of superior strength, as the five armed assailants collectively overwhelmed the unarmed victim. The penalty of reclusion perpetua was upheld, with an order for civil indemnity and actual damages.