GR 105672; (August, 1996) (Digest)
G.R. No. 105672 August 22, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. WILFREDO LUAYON @ “Willy,” et al., accused-appellants.
FACTS
The case involves the murder of former barangay captain Alejandro Castillon. On January 12, 1987, Castillon was invited to a drinking session at the store of accused Nestor Patigue. Later that night, eyewitnesses Ernan Ayop and Ronnie Custodio saw accused Wilfredo Luayon strike Castillon on the head with a piece of wood and an iron bar. Other accused, including Alfredo Sabior, Jacinto Moreng, and Rodolfo Toniacao, were allegedly present. The following day, Castillon was reported missing. Police investigation at Patigue’s store revealed bloodstains and other evidence of violence. Castillon’s body was later found some distance away. During investigation, Toniacao confessed and drew a sketch leading to the body’s location. Luayon, upon arrest, admitted to the killing and led police to the victim’s buried firearm and wallet.
The Regional Trial Court convicted Luayon, Sabior, Moreng, Toniacao, and Patigue of murder, sentencing them to reclusion perpetua. The accused appealed, challenging the credibility of witnesses and the sufficiency of evidence for conspiracy.
ISSUE
Whether the prosecution proved the guilt of the accused beyond reasonable doubt, particularly the existence of conspiracy to commit murder.
RULING
The Supreme Court modified the decision. It acquitted Sabior, Moreng, and Toniacao due to insufficient evidence of conspiracy. The Court found that mere presence at the scene, without any proven overt act to facilitate the crime, does not establish conspiracy. The testimonies did not clearly show that these accused had prior agreement or collective criminal intent with Luayon. However, the Court affirmed Luayon’s criminal liability, but reduced the crime from Murder to Homicide. The qualifying circumstance of treachery was not established, as the prosecution failed to prove how the attack was commenced; the eyewitnesses only saw the blows being delivered, not the manner of inception. The Court also noted the trial court’s error in appreciating evident premeditation without clear proof of planning. Luayon was sentenced to an indeterminate penalty of 6 years and 1 day of prision mayor as minimum to 14 years and 8 months of reclusion temporal as maximum. The case against Patigue, who remained at large, was ordered archived pending his arrest.