G.R. No. 110405 . January 2, 1997.
People of the Philippines, plaintiff-appellee, vs. Virgilio Tañedo, Berlito Lachica, and Danilo Mercadal, accused-appellants.

FACTS

On the evening of April 25, 1982, Domingo and Dominador Nepal passed by a store in Barangay San Isidro, General Luna, Quezon. An altercation ensued at the store involving Ruben Agoncillo and Jesus Lachica, which Domingo helped pacify. Danilo Mercadal and Berlito Lachica were present. Later, as Domingo and Dominador were walking home, Virgilio Tañedo, Berlito Lachica, Jesus Lachica, Danilo Mercadal, and two others, all armed with bladed weapons, suddenly emerged from a banana grove and a nearby house. Danilo hacked Domingo on the head. The group then surrounded Domingo, and Virgilio delivered a final stab with a balisong. Domingo died from his wounds. Their mother, Maxima Remuyan, witnessed the attack from a short distance.
The accused were charged with murder. At trial, the accused appellants denied involvement, presenting alibis and pointing to other individuals as the perpetrators. The trial court convicted all six accused of murder, finding conspiracy and treachery. On appeal to the Court of Appeals, the conviction was affirmed for Tañedo, Lachica, and Mercadal. The case was elevated to the Supreme Court for final review.

ISSUE

Whether the accused-appellants are guilty of murder qualified by treachery.

RULING

Yes, the Supreme Court affirmed the conviction for murder. The Court found the testimonies of the prosecution witnesses, particularly Dominador Nepal and Maxima Remuyan, to be clear, consistent, and credible. Their positive identification of the appellants as participants in the concerted assault prevailed over the weak defenses of denial and alibi, which were not substantiated by clear and convincing evidence.
The legal logic for finding murder qualified by treachery is sound. Treachery exists when the offender employs means, methods, or forms of execution that deliberately and directly ensure the act’s completion without risk to themselves from any defense the victim might offer. The evidence established that the appellants, together with their cohorts, lay in wait for the victim, armed themselves, and emerged suddenly from concealment to launch a synchronized attack on the unarmed Domingo. This surprise assault, executed by a group against a solitary individual, rendered the victim completely unable to defend himself. The manner of attack directly and specially insured the killing’s execution without risk to the assailants. Thus, the qualifying circumstance of treachery was present, elevating the homicide to murder. The Court modified the penalty to reclusion perpetua in accordance with the law.