G.R. Nos. 108280-83 and 114931-33, November 16, 1995
Romeo Sison, Nilo Pacadar, Joel Tan, Richard de los Santos, and Joselito Tamayo, petitioners, vs. People of the Philippines and Court of Appeals, respondents. / People of the Philippines, plaintiff-appellee, vs. Annie Ferrer, accused, Romeo Sison, et al., accused-appellants.

FACTS

On July 27, 1986, during a period of intense political rivalry following the EDSA Revolution, a group of Marcos loyalists held an unauthorized rally at Luneta. After police dispersed the rally, a smaller group converged at the Chinese Garden. Movie starlet and Marcos supporter Annie Ferrer, upon learning of the dispersal, angrily chanted slogans urging her supporters to attack “Cory hecklers.” Shortly thereafter, Stephen Salcedo, a known “Coryista” wearing a yellow shirt, was identified and chased by a mob shouting “Cory iyan!”
Multiple eyewitnesses, including Renato Banculo and Ranulfo Sumilang, testified to seeing the accused-appellants—Romeo Sison, Nilo Pacadar, Joel Tan, Richard de los Santos, and Joselito Tamayo—actively participate in the brutal and sustained mauling of Salcedo. The attack involved punching, kicking, and hitting the victim with stones. Despite Sumilang’s attempts to intervene, the assault continued across different locations within Luneta until Salcedo collapsed. He was pronounced dead upon arrival at the hospital due to traumatic intracranial hemorrhage.

ISSUE

The core issue is whether the accused-appellants are guilty of murder beyond reasonable doubt, considering their defenses of denial and alibi, and the sufficiency of the prosecution’s evidence to establish conspiracy and the qualifying circumstance of treachery.

RULING

The Supreme Court affirmed the conviction of the accused-appellants for the crime of Murder. The Court found the testimonies of the prosecution eyewitnesses, Banculo and Sumilang, to be credible, consistent, and sufficient to establish the appellants’ individual participation in the killing. Their positive identification overcame the weak defenses of denial and alibi, which were not corroborated by clear and convincing evidence.
The Court ruled that conspiracy was proven by the appellants’ collective and simultaneous actions in pursuing, attacking, and mauling Salcedo in response to a common exhortation to assault “Coryistas.” Their concerted efforts showed a unity of purpose and design. Furthermore, the Court found that treachery (alevosia) attended the killing. The attack was sudden and unexpected, executed in a manner that deprived the unarmed and outnumbered victim of any chance to defend himself. The sustained and brutal nature of the assault from different angles ensured the execution of the crime without risk to the appellants. The Court modified the damages awarded but sustained the penalty of reclusion perpetua for each appellant.