G.R. No. 112369. April 4, 1997.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JACINTO APONGAN alias VER, accused-appellant.

FACTS

Accused-appellant Jacinto Apongan, along with Ronald Revadona, was charged with the murder of Victoria Samulde. The prosecution’s sole eyewitness, Celestino Samulde Jr., the victim’s son, testified that on the evening of June 8, 1986, while walking with his mother, they encountered Apongan and Revadona. Without warning, Revadona attempted to grab Celestino, who evaded and ran. Looking back, Celestino saw both Apongan and Revadona repeatedly stabbing his mother with long knives under illumination from a nearby poultry bulb, enabling his clear identification of the assailants.
Apongan admitted his presence at the scene but denied participation, claiming another uncharged individual was the sole perpetrator. He argued the eyewitness testimony was unreliable due to alleged inconsistencies and poor lighting. The trial court convicted Apongan and Revadona of murder qualified by treachery, sentencing them to reclusion perpetua. Apongan appealed, challenging the credibility of the eyewitness and the finding of conspiracy.

ISSUE

The core issue is whether the trial court erred in convicting Apongan based on the eyewitness identification and in finding conspiracy between him and Revadona.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of Celestino Samulde Jr.’s credibility, finding no cogent reason to deviate from its findings. The witness had a clear view of the assailants, whom he knew as neighbors, under sufficient illumination from a nearby electric bulb. Minor inconsistencies in his testimony pertained to collateral matters and did not undermine the core narrative of the killing. The positive identification by a credible eyewitness prevails over Apongan’s bare denial and unsubstantiated alibi.
Regarding conspiracy, the Court ruled it was sufficiently established by the coordinated actions of Apongan and Revadona. Their simultaneous attack on the victim, with one attempting to neutralize the son while both actively stabbed the mother, demonstrated a unity of purpose and design. Treachery was correctly appreciated as the mode of attack was sudden and unexpected, depriving the victim of any chance to defend herself. The Court also noted that the circumstance of abuse of superior strength, while present, is absorbed in treachery. Consequently, the penalty of reclusion perpetua and the award of civil indemnity were affirmed.