G.R. No. 107329 January 24, 1994
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANILO MANALO Y LATAG, VICENTE VILLAPANDO Y ROXAS, ANTONIO FAJARDO Y CARINO AND JOSE MANALO Y LATAG, accused-appellants.

FACTS

Accused-appellants Danilo Manalo, Vicente Villapando, Antonio Fajardo, and Jose Manalo were charged with Murder before the Regional Trial Court of Lemery, Batangas. The amended information alleged that on June 5, 1983, at about 1:30 a.m. in Alitagtag, Batangas, the accused, conspiring and armed with a hunting knife, ice-pick, and fan knife (balisong), with treachery and evident premeditation, attacked and stabbed Patrolman Edilberto Arguelles, inflicting multiple stab wounds that caused his instantaneous death, with the aggravating circumstance of abuse of superior strength.
The prosecution’s evidence established that Rosana Balino was waiting for a ride near the church when Pat. Arguelles assisted her. A group of men, including the accused, arrived. Arguelles warned Rosana about them and later admonished the group for lifting a wooden barricade. The group proceeded to a store. Later, Rosana heard one of them shout provocations. Arguelles emerged, fired a warning shot, and approached the group. A scuffle ensued, and Arguelles told Rosana to fetch help. Eyewitness Crispin Badillo, who was in his house nearby, heard a gunshot and saw the four accused ganging up on Arguelles, who was already on the ground. While Antonio Fajardo wrestled Arguelles’s .45 caliber pistol away from him, the other three accused repeatedly stabbed the victim with their weapons. After about ten minutes, the accused fled. Arguelles staggered and collapsed. He sustained eighteen stab wounds and died from hemorrhage. The police found a bloodstained balisong, a deformed slug, two empty shells, and bloodstained clothing at the scene.
The accused pleaded not guilty. Danilo Manalo claimed self-defense, alleging that Arguelles accosted him without reason, fired his gun, and aimed it at his head, prompting Danilo to stab him with a balisong. He claimed his companions had already fled. The other accused generally corroborated that they ran away upon hearing a gunshot and denied participation.
The trial court found all accused guilty of Murder qualified by abuse of superior strength and sentenced them. The Court of Appeals affirmed the factual findings but modified the penalty to reclusion perpetua and increased the civil indemnity to P50,000.00, then certified the case to the Supreme Court.

ISSUE

Whether the accused-appellants are guilty of Murder qualified by abuse of superior strength.

RULING

The Supreme Court AFFIRMED the decision of the appellate court. The Court upheld the credibility of prosecution witnesses Crispin Badillo and Rosana Balino, noting the trial court’s superior position to assess witness demeanor. The place of the incident was well-illuminated by multiple light sources, enabling clear identification. The accused-appellants conspired and took advantage of their combined strength to overpower the victim. While the victim was armed with a gun, accused Fajardo wrestled it away while the others simultaneously stabbed him, rendering the gun ineffective. The killing was thus qualified by abuse of superior strength. The penalty of reclusion perpetua was imposed, and accused-appellants were ordered to indemnify the heirs of Patrolman Edilberto Arguelles in the amount of fifty thousand pesos (P50,000.00).