GR 227013; (June, 2019) (Digest)
G.R. No. 227013 June 17, 2019
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. ARIES REYES Y HILARIO AND DEMETRIO SAHAGUN Y MANALILI, Accused-Appellants
FACTS
The accused-appellants, Aries Reyes and Demetrio Sahagun, along with two others at large, were charged with Murder for the death of Jun Balmores. The prosecution alleged that on August 5, 2007, in Manila, an argument ensued between the victim and the accused over vending space. Later, the accused pursued Balmores. Sahagun struck him with a plastic chair, causing him to fall. Reyes and another then hit him with broomsticks. As the victim tried to flee, he was intercepted and stabbed twice by another accused, Argie Reyes. The victim died from hypovolemic shock secondary to a stab wound. The defense presented an alibi, claiming appellants were playing cards elsewhere and only arrived after the stabbing incident perpetrated solely by Argie Reyes.
ISSUE
Whether the Court of Appeals correctly affirmed the conviction of appellants Aries Reyes and Demetrio Sahagun for the crime of Murder.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the prosecution evidence, particularly the credible and consistent testimonies of eyewitnesses Catherine Balmores (the victim’s wife) and Mary Ann Nuñez, sufficient to establish appellants’ guilt beyond reasonable doubt. These witnesses positively identified appellants as active participants in the concerted attack. Their narration detailed how Sahagun initiated the assault by hitting the victim with a chair, and how Reyes, together with others, beat the fallen victim with broomsticks, rendering him defenseless. This collective violence facilitated the fatal stabbing by their co-accused.
The qualifying circumstance of treachery was correctly appreciated. The attack was sudden and unexpected, executed in a manner that denied the victim any opportunity to defend himself or retaliate. The initial blow from the chair rendered him vulnerable, and the subsequent beating with broomsticks by the group, including appellant Reyes, ensured he could not escape or fight back, thereby guaranteeing the execution of the fatal assault without risk to the assailants. The Court modified the damages awarded in accordance with prevailing jurisprudence, affirming the penalty of reclusion perpetua without eligibility for parole. The defense of alibi was rightly rejected for being weak and unsubstantiated against the positive identification by credible witnesses.