G.R. No. 118079 December 24, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARMANDO ESTANISLAO, ROGELIO ESTANISLAO, and FELINO ESTANISLAO [Deceased], accused-appellants.

FACTS

The accused, Armando, Rogelio, and Felino Estanislao, were charged with the murder of Sergio Montejo. The prosecution’s eyewitness, Fe Peñaredondo, testified that on January 19, 1990, Rogelio suddenly stabbed Montejo as the latter stood up from a drinking session. She claimed Armando and Felino, who were nearby carrying wooden sticks, approached the fallen victim and then fled. The victim’s wife, Araceli Montejo, testified to prior animosity, including a fistfight days before the killing and a threat from Rogelio.
The defense presented a contradictory account. Rogelio claimed self-defense, alleging Montejo and companions attacked him with bottles and bladed weapons, and the fatal wound was accidental when he parried a bolo strike. Armando relied on alibi, stating he was working elsewhere, though the location was minutes from the crime scene. Felino died pending trial.

ISSUE

The core issues were: (1) whether the killing was attended by treachery and evident premeditation to qualify as murder; (2) whether conspiracy existed among the accused; and (3) the validity of Rogelio’s claim of self-defense.

RULING

The Supreme Court modified the trial court’s decision. It upheld Rogelio Estanislao’s conviction for murder but acquitted Armando Estanislao and set aside the liability of Felino’s estate.
On the qualifying circumstances, treachery was sufficiently established. The attack was sudden and unexpected, giving the unarmed victim no opportunity to defend himself. However, evident premeditation was not proven, as the prosecution failed to show clear evidence of the accused’s prior plan and a sufficient lapse of time for reflection.
Conspiracy was not established against Armando and the deceased Felino. Their mere presence at the scene and relationship to Rogelio, without proof of any concerted action or direct participation in the stabbing, were insufficient to infer a common criminal purpose. The doubt was resolved in their favor.
Rogelio’s claim of self-defense failed. His testimony was uncorroborated on material points and inconsistent with the physical evidence and the credible account of the eyewitness. The mitigating circumstance of voluntary surrender was also not appreciated, as his surrender was not spontaneous. Consequently, Rogelio was correctly found guilty of murder and sentenced to reclusion perpetua, with an order to pay indemnity to the victim’s heirs.