G.R. No. 111289. August 11, 1995.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VICTOR TORRES, MARIO EMNACE, EDUARDO EMNACE, and LIBERATO RAYMUNDA, accused-appellants.

FACTS

Accused-appellants Victor Torres, Mario Emnace, Eduardo Emnace, and Liberato Raymunda, along with Eduardo Torres, were charged with Murder for the killing of Avelino Villaplaza on October 21, 1989. Eduardo Torres pleaded guilty to homicide. The remaining four pleaded not guilty, were tried, and were convicted of Murder and sentenced to reclusion perpetua. They appealed, arguing that Eduardo Torres’s guilty plea negated conspiracy, that prosecution witnesses were not credible, and that treachery was erroneously appreciated.
The prosecution evidence established that the victim and his companions went to Raymunda’s store after a dance. Raymunda approached the victim, placed an arm around his shoulder, and Eduardo Emnace pushed him from behind, causing him to fall. Raymunda then pinned the victim to the ground. Victor Torres, Eduardo Torres, and Mario Emnace, armed with a knife, scythe, and plamingko respectively, simultaneously attacked and stabbed the helpless victim. The autopsy revealed multiple fatal wounds on the head, neck, and forearm, which the medico-legal officer opined were inflicted by more than one person using sharp bladed instruments.

ISSUE

Whether the trial court erred in convicting accused-appellants of Murder based on conspiracy, crediting prosecution witnesses, and appreciating the qualifying circumstance of treachery.

RULING

The Supreme Court affirmed the conviction. The legal logic is threefold. First, conspiracy was proven beyond reasonable doubt by the appellants’ coordinated actions leading to the attack. The act of one is the act of all. Eduardo Torres’s separate plea of guilty to homicide does not absolve the others, as conspiracy can still exist and be proven independently. The medico-legal finding that the wounds were inflicted by more than one person corroborated the eyewitness accounts of a concerted attack.
Second, the positive identification by credible prosecution witnesses prevails over the appellants’ bare denial. The trial court’s assessment of witness credibility is accorded great respect, as it is in the best position to observe demeanor. No compelling reason was shown to overturn this finding. The witnesses clearly detailed how each appellant participated in immobilizing and attacking the victim.
Third, treachery was correctly appreciated. The means of execution—luring the victim, suddenly pushing him down, pinning him to immobilize him, and then launching a synchronized attack with bladed weapons—ensured the execution of the killing without any risk to the appellants arising from the victim’s defense. The victim was rendered helpless and unable to retaliate or escape, satisfying the criteria for treachery. Thus, the crime was properly qualified as Murder.