G.R. No. 108662 . June 27, 1995.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FERNANDO HALILI y NAVARRO and MANUEL PALTING, accused-appellants.

FACTS

Accused-appellants Fernando Halili and Manuel Palting, bodyguards for the Laoag City Mayor, were charged with two counts of murder for the killings of police officers Leonico Acpal and Oscar Duldulao. The incident originated from an altercation at the Colonial Fastfood Restaurant on November 27, 1990. Pat. Acpal disarmed Halili after Halili aimed a gun at a fleeing customer. The firearm was later returned by a police lieutenant. Humiliated, Halili left, changed into combat gear, armed himself with an M-16 Armalite rifle, and returned to the restaurant after midnight.
Upon his return, Halili, without warning, shot Pat. Acpal point-blank at the back of the head, killing him instantly with multiple gunshot wounds. Simultaneously, as Pat. Duldulao attempted to flee, Manuel Palting shot him with a .22 caliber revolver. When Duldulao fell, Palting took Duldulao’s own service pistol and shot him again, causing his death. Both accused then fled together to a military brigade headquarters.

ISSUE

The core issue is whether the accused-appellants are guilty of murder, qualified by treachery, for the separate killings of the two police officers.

RULING

The Supreme Court affirmed the convictions but modified the ruling by holding each appellant liable only for the death of a specific victim, rejecting the trial court’s finding of a single conspiracy for both killings. The Court found no evidence of a prior agreement between Halili and Palting to kill both officers. Halili’s motive was personal vengeance against Acpal for the disarming incident. Palting’s spontaneous act of killing Duldulao, who was attempting to respond or flee during the sudden attack on his partner, constituted a separate criminal act.
The legal logic for murder rests on the presence of treachery. For Halili, the attack on Acpal was treacherous because Acpal was seated with his back to the entrance, completely unaware and unable to defend himself, ensuring the execution without risk to Halili. For Palting, the attack on Duldulao was likewise treacherous. Duldulao was caught by surprise in the immediate, violent aftermath of Acpal’s shooting, with Palting exploiting the suddenness and confusion to attack without any opportunity for Duldulao to put up a defense. The qualifying circumstance of treachery attended each killing independently. Thus, each appellant was correctly sentenced to reclusion perpetua for the murder each personally committed.