GR 108598; (September, 1995) (Digest)
G.R. No. 108598 September 21, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RONNIE AMANIA, MANUEL AMANIA, GERMINIANO DANONG, GREGORIO CALIZA alias Goring, EFREN LUCABON, ERNESTO PIAMONTE, JR., and DANILO PERAS, accused-appellants.
FACTS
On March 1, 1988, Police Officer Douglas Deguilmo was gunned down near his residence in San Jose Village, Mandaue City, while walking to work with his wife, Cecilia Deguilmo. Cecilia, the principal eyewitness, identified brothers Ronnie and Manuel Amania as the gunmen. She testified that the other appellants—Gregorio Caliza, Germiniano Danong, Efren Lucabon, Ernesto Piamonte, Jr., and Danilo Peras—acted as lookouts. Another witness, Feliciano Hortelano, heard gunfire and saw Ronnie Amania and Germiniano Danong fleeing the scene armed with handguns. All accused were apprehended on the same day based on reports and were positively identified by Cecilia in a police line-up and in court.
The appellants uniformly denied involvement, presenting alibis that they were at their respective homes or workplaces during the incident. After trial, the Regional Trial Court found all accused guilty of murder, qualified by treachery and aggravated by abuse of superior strength, sentencing them to reclusion perpetua. Ronnie Amania escaped custody and remained at large. The other six appellants appealed the decision.
ISSUE
Whether the trial court erred in convicting the accused-appellants of murder based on the eyewitness identification and evidence presented by the prosecution.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of Cecilia Deguilmo’s credibility, rejecting the appellants’ claim that her identification was unreliable due to the traumatic event. The Court emphasized that testimonies of witnesses are not rendered incredible merely because they are relatives of the victim, especially when, as here, the witness had a clear and unobstructed view of the assailants. The defense of alibi was correctly dismissed for being weak and unsubstantiated, particularly as the appellants failed to prove it was physically impossible for them to be at the crime scene.
The Court found conspiracy was established through the appellants’ coordinated actions before, during, and after the shooting, demonstrating a community of criminal purpose. The killing was qualified as murder by treachery (alevosia), as the attack was sudden, from behind, and without warning, deliberately adopted to ensure the execution without risk to the assailants. The circumstance of abuse of superior strength was correctly held to be absorbed by treachery. The penalty of reclusion perpetua was thus proper. The appeal was dismissed and the trial court’s judgment affirmed in toto.