G.R. No. 190862 ; October 9, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RICARDO DEARO, PAULINO LUAGUE and WILFREDO TOLEDO, Accused-Appellants.

FACTS

On the evening of February 26, 1996, Jose Jaro, Emeterio Santiago, his son Rolly, Porferia Luague Guardario, and her daughter Analiza were at a fiesta in Bugay, Bayawan, Negros Oriental. Around midnight, the group proceeded to Jose’s house to spend the night. As Jose and Rolly approached the house, they heard a gunshot and saw Paulino Luague coming down from the house, saying, “Ti, tapos ka man!” They then heard cries for help from inside, followed by rapid gunfire from the back of the house. After the firing stopped, they saw appellants Ricardo Dearo and Wilfredo Toledo, both carrying long firearms, walk with Luague from the back of the house. Inside, they found Emeterio and Porferia dead; Analiza was still alive but later died at the hospital. The initial police investigation yielded no information from witnesses. A subsequent investigation by the CIS revealed a land dispute between the Luague family heirs, specifically between Paulino Luague and his sister Porferia. Emeterio Santiago, appointed as overseer of the land, had angered Luague. A few days before the shooting, on February 24, 1996, Luague, Dearo, and Toledo went to the property, where Dearo publicly threatened to kill Emeterio within three days. Marcelo Guardario, Porferia’s husband, confirmed Luague had repeatedly threatened Porferia’s life over the dispute. Appellants were charged with three counts of murder. During trial, appellant Dearo interposed denial and alibi, claiming he was at the fiesta and learned of the incident only from police the next day. The RTC found all three accused guilty based on circumstantial evidence, conspiracy, and the qualifying circumstances of treachery and evident premeditation, sentencing them to reclusion perpetua for each count. The CA affirmed the RTC decision with modifications to the damages awarded. Paulino Luague died during appeal, leaving only Dearo and Toledo as appellants.

ISSUE

Whether the guilt of appellants Ricardo Dearo and Wilfredo Toledo was proven beyond reasonable doubt.

RULING

Yes. The Supreme Court denied the appeal and affirmed the convictions. The prosecution established guilt through circumstantial evidence under Section 4, Rule 133 of the Rules of Court. The combination of proven circumstances was consistent with guilt and inconsistent with innocence, producing conviction beyond reasonable doubt. These circumstances included: (1) the land dispute and prior threats by Luague against Porferia and by Dearo against Emeterio; (2) the presence and coordinated actions of Luague, Dearo, and Toledo at the crime scene immediately after the shooting; (3) the discovery of the victims immediately thereafter; and (4) the lack of evidence for appellants’ defenses of denial and alibi. The Court affirmed the presence of conspiracy, treachery (as the attack was sudden and the victims were unarmed and inside a house), and evident premeditation (based on the prior public threat). The penalty of reclusion perpetua for each count of murder was upheld. The awards of civil indemnity, moral damages, temperate damages, and exemplary damages, as modified by the CA, were also affirmed.