G.R. No. 114812 June 19, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODEL Z. SAHAGUN @ “ROD SAKSAK”, ERNESTO F. VILLAREAL @ “WONG” and FERNANDO BONIFACIO @ “KISKIS” (At Large), accused-appellants.

FACTS

Accused-appellants Rodel Sahagun and Ernesto Villareal, along with Fernando Bonifacio (at large), were charged with Murder for the killing of Michelle Avendaño on August 1, 1993, in Caloocan City. The prosecution’s case rested primarily on the eyewitness account of Joselito dela Cruz. Dela Cruz testified that he was invited by the three accused to a drinking session at Sahagun’s house, where he overheard their plan to abduct, rape, and kill a girl. Sahagun revealed a personal grudge against Michelle Avendaño. The group, using a tricycle driven by Bonifacio, later abducted Avendaño as she left her workplace. They brought her to the Maria Clara Elementary School, where Sahagun dropped an adobe rock on her head, and Villareal and Bonifacio stabbed her. Dela Cruz acted as a lookout. The victim’s body was discovered on August 3, 1993. Dela Cruz later surrendered and gave sworn statements to the NBI. Both accused-appellants pleaded not guilty and raised the defense of denial and alibi. They also claimed their extra-judicial confessions were extracted through torture and that their right to counsel was violated. The Regional Trial Court convicted Sahagun and Villareal of Murder and sentenced them to reclusion perpetua, ordering them to pay indemnity and damages.

ISSUE

The main issues were: (1) the credibility of the prosecution’s eyewitness, Joselito dela Cruz; (2) the admissibility of the extra-judicial confessions of the accused-appellants; and (3) whether the prosecution proved the guilt of the accused-appellants beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court held that the testimony of eyewitness Joselito dela Cruz was credible and sufficient to establish guilt beyond reasonable doubt. The minor discrepancies in his testimony were deemed insignificant and natural for a witness to a shocking crime. The Court also ruled that the extra-judicial confession of appellant Villareal was inadmissible as it was obtained without the benefit of effective and independent counsel, violating his constitutional rights. However, even without these confessions, the direct and detailed testimony of dela Cruz, who witnessed the planning and execution of the crime, provided ample basis for conviction. The defenses of denial and alibi were weak and could not prevail over the positive identification by the eyewitness. The decision of the trial court was affirmed in toto.