GR 104870; (August, 1996) (Digest)
G.R. No. 104870 August 22, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. AMADEO BRONCANO, HERNANI BRONCANO, GUILLERMO BRONCANO, DIOSDADO BRONCANO, DIOSCORO BRONCANO and ANTONIO VARELA, accused-appellants.
FACTS
On April 5, 1990, during a fiesta in Malinao, Albay, the accused-appellants were drinking near a cockpit when the victim, Renato Canuel, passed by. After being invited to join, Canuel accidentally knocked over Amadeo Broncano’s glass, prompting Amadeo to assault him. Canuel left, and Amadeo shouted a death threat. Later, Amadeo, his sons Hernani and Guillermo, and their relatives Diosdado, Dioscoro, and Antonio Varela, armed with bolos, barged into the house of Eduardo Bello, Canuel’s brother-in-law, searching for him. Diosdado located Canuel hiding behind banana plants and alerted the group. Amadeo struck first, hitting Canuel on the forehead, after which the group collectively hacked him for about four minutes. Guillermo returned to deliver a final stab to the throat. The victim was found dead with multiple severe wounds.
The defense presented a contradictory version, claiming Canuel initially stabbed Amadeo, and only Guillermo fought back in defense of his father, inflicting all wounds. Other accused asserted alibis. The trial court convicted all accused of Murder qualified by treachery and superior strength, sentencing them to reclusion perpetua.
ISSUE
Whether the trial court correctly convicted the accused-appellants of the crime of Murder.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the prosecution’s evidence, particularly the credible and straightforward testimonies of eyewitnesses Eduardo and Efren Bello, sufficient to establish conspiracy and guilt beyond reasonable doubt. The defense of alibi was properly rejected as the accused were not far from the crime scene. The claim that only Guillermo acted in defense of his father was untenable. The medical finding that wounds were inflicted by different bladed weapons contradicted the single-assailant theory. Furthermore, the excessive number of wounds, including a final stab to the throat, negated any claim of lawful defense, demonstrating a deliberate intent to kill.
The crime was Murder qualified by treachery, as the attack on the unarmed and hiding victim was sudden and denied him any chance to defend himself. The aggravating circumstances of evident premeditation and nighttime were correctly disregarded by the Supreme Court for lack of conclusive proof. Superior strength was deemed absorbed in treachery. Thus, the penalty of reclusion perpetua was affirmed.