G.R. Nos. 115247-48; December 1, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GASPAR S. SINDA, ROMEO S. SINDA and ERNESTO S. SINDA, accused-appellants.

FACTS

The appellants, brothers Gaspar, Romeo, and Ernesto Sinda, were convicted of murder for the deaths of Felix and Rogelio Salacut. The prosecution evidence established that on September 16, 1993, the appellants and the victims were engaged in a drinking session at the appellants’ parents’ house. An altercation ensued when Felix Salacut repeatedly asked appellant Gaspar about the location of his bolo. Irked, Gaspar punched Felix, causing him to fall. The three appellants then pelted the fallen Felix with stones. They subsequently turned on Rogelio Salacut, who was lying nearby, and similarly stoned him. The attack was witnessed by Benceslao Silorio. The autopsy reports revealed both victims died from shock and hemorrhage due to severe head injuries and stab or incised wounds.
The appellants presented a different version. Appellant Gaspar claimed self-defense, alleging that Felix attacked him with a bolo, prompting him to throw a stone, pick up the dropped bolo, and stab Felix. He further claimed Rogelio also attacked him, leading to a struggle where Rogelio was fatally wounded. Appellant Romeo asserted he was merely present and did not participate, while appellant Ernesto invoked alibi, claiming he was inside the house during the incident.

ISSUE

The core issue is whether the trial court correctly convicted the appellants of murder, rejecting their defenses of self-defense, denial, and alibi.

RULING

The Supreme Court affirmed the convictions. The Court meticulously dismantled the appellants’ defenses. For Gaspar’s claim of self-defense, the Court found his narrative inherently unbelievable and inconsistent with the physical evidence. The nature, number, and severity of the victims’ wounds—multiple lacerations and fractures from stoning, coupled with stab wounds—were grossly disproportionate to any purported defensive action and indicated a determined effort to kill, negating self-defense. The positive identification by eyewitness Silorio, who had no ill motive to testify falsely, was credited over the appellants’ denials.
The Court also rejected the defenses of Romeo and Ernesto. Conspiracy was duly proven by their collective and coordinated actions in simultaneously assaulting the helpless victims, demonstrating a unity of purpose. Ernesto’s alibi failed because he was only meters away inside the house, making it not physically impossible for him to be at the scene. His alibi crumbled against Silorio’s positive identification. The qualifying circumstance of treachery was correctly appreciated, as the victims, having been knocked down and rendered defenseless by the initial assault, were attacked in such a manner that they had no opportunity to defend themselves. The Court thus upheld the penalties of reclusion perpetua for each appellant.