G.R. No. 116280 May 21, 2001
The People of the Philippines, plaintiff-appellee, vs. Paquito Dumayan, accused-appellant.

FACTS

The appellant, Paquito Dumayan, along with three others, was charged with the murder of Carlito Tamayo on February 1, 1992, in Malolos, Bulacan. The prosecution presented eyewitnesses Anastacia Tamayo, the victim’s common-law wife, and Emilia Santos, a neighbor. Anastacia testified that she heard her husband cry out after being attacked by the group as he was about to climb the stairs of their house. She then saw him being chased along the railway, overtaken, and simultaneously stabbed by his pursuers, with appellant specifically stabbing the victim at the back with a bolo. Emilia Santos corroborated this account, detailing how the group, including appellant, attacked the victim at different points during the chase. The victim sustained six fatal stab and hack wounds. The defense interposed alibi, claiming appellant was at a construction site working at the time of the crime. Appellant and a co-worker presented a payroll sheet to support his presence at work, and a civic leader testified she saw him leave for work that morning and return in the afternoon, not during the incident.

ISSUE

The core issue is whether the prosecution proved the guilt of appellant Paquito Dumayan for the crime of murder beyond reasonable doubt, overcoming his defense of alibi.

RULING

The Supreme Court affirmed the conviction. The Court found the positive identification by two credible eyewitnesses, who had no ill motive to testify falsely, to be categorical and consistent. Their testimonies established that appellant actively participated in the concerted attack. The defense of alibi was correctly rejected as it was not physically impossible for appellant to have been at the crime scene, given that his alleged workplace was within the same municipality. The Court upheld the trial court’s assessment of witness credibility, which is accorded great respect. The qualifying circumstance of treachery was properly appreciated because the attack was sudden and unexpected, denying the victim any opportunity to defend himself. The Court also found conspiracy, as the malefactors’ simultaneous and coordinated actions in chasing and stabbing the victim demonstrated a common purpose to kill. However, the Court agreed with the appellant that evident premeditation was not proven, as the prosecution failed to establish the time of the criminal decision and a sufficient reflective period. Thus, appellant was correctly found guilty as a principal by direct participation and by conspiracy. The penalty of reclusion perpetua and the award of civil indemnity were affirmed.