AC- G.R. No. 25034 -CR April 11, 1984
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARIO NAVOA, RICARDO SITCHON and RAFAEL NAVOA, accused-appellants.

FACTS

Accused-appellants Mario Navoa, Rafael Navoa, and Ricardo Sitchon were convicted of Murder for the killing of Tomas Izon on January 21, 1976, in Abucay, Bataan, and sentenced to an indeterminate penalty. The prosecution established a motive rooted in a landlord-tenant dispute over a two-hectare parcel of land. In May 1975, state witness Macario Saguinza testified that the Navoas and Sitchon offered him P3,000 to kill Izon. Upon his refusal, they declared they would do it themselves. On the night of the killing, eyewitness Baltazar dela Rosa saw three men, including the positively identified Ricardo Sitchon, approach Izon from behind near a farm hut and heard successive gunshots. Izon died from multiple gunshot wounds, mostly in the back.
The appellants denied involvement, separately invoking alibi. Rafael and Mario Navoa claimed they were at home watching television, while Sitchon asserted he was at a wake approximately fifty meters from the crime scene. They challenged the credibility of Saguinza, alleging inconsistencies in his statements, and argued that no conspiracy was proven.

ISSUE

The core issues were whether the trial court erred in: (1) believing the testimony of Macario Saguinza and finding a conspiracy among the accused; (2) giving credence to the testimony of Baltazar dela Rosa implicating Ricardo Sitchon; and (3) convicting the accused of Murder.

RULING

The Appellate Court affirmed the conviction but modified the penalty. It found no merit in the appellants’ contentions. The testimony of Macario Saguinza was deemed credible and consistent across his statements, all uniformly detailing the appellants’ offer to hire him for the killing and their subsequent decision to perpetrate it themselves when he refused. The court found no ill motive for Saguinza to falsely testify against the appellants. The eyewitness account of Baltazar dela Rosa, who positively identified Sitchon at the scene under illumination from a gas lamp, was found credible and sufficient to establish Sitchon’s direct participation.
The legal logic for finding conspiracy was based on the appellants’ collective actions before and during the crime. Their prior joint offer to Saguinza demonstrated a common purpose to eliminate Izon. Their concerted action in approaching the victim from behind at night and simultaneously shooting him established a unity of purpose and execution. The killing was qualified by treachery, as the attack was sudden and from behind, rendering the victim defenseless. Evident premeditation was also present, evidenced by the planning eight months prior. The defenses of alibi were rightly rejected for being weak and unsubstantiated. However, the court corrected the penalty, ruling that for Murder under Article 248 of the Revised Penal Code, with no modifying circumstances, the proper penalty is reclusion perpetua, not the minimum period imposed by the trial court. The case was certified to the Supreme Court for final judgment on the modified penalty.