GR 119477; (February, 2003) (Digest)
G.R. No. 119477 ; February 27, 2003
EDDIE TALAY, BAYANI TALAY and EDGARDO MAIGUE, JR., petitioners, vs. COURT OF APPEALS and PEOPLE OF THE PHILIPPINES, respondents.
FACTS
An Information for homicide was filed against petitioners Eddie Talay, Bayani Talay, and Edgardo Maigue, Jr., along with two others at large, for the shooting death of Ronaldo Montoya on December 26, 1981, in Silang, Cavite. The prosecution’s eyewitnesses, including the victim’s companion and a store owner, testified that the group of petitioners arrived at a store, initiated a mauling against Montoya and his friend, and that after the victim reported the incident to a barangay official and pointed to petitioners, Maigue shouted “Barilin na iyan!” prompting Eddie Talay to shoot Montoya twice with a .45 caliber pistol, causing his death.
The defense presented an alibi, claiming they were merely bystanders and that an unidentified man was the shooter. The Regional Trial Court convicted petitioners of homicide, a decision affirmed with modification by the Court of Appeals, which upheld the conviction but deleted exemplary damages and awarded civil indemnity. Petitioners elevated the case to the Supreme Court via a petition for review.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of petitioners for the crime of homicide based on the evidence presented.
RULING
The Supreme Court affirmed the conviction. The Court found the testimonies of the prosecution witnesses credible, consistent, and sufficient to establish petitioners’ guilt beyond reasonable doubt. The positive identification by eyewitnesses who had no motive to falsely testify prevailed over the denial and alibi of the petitioners. The Court emphasized that alibi is inherently weak and cannot stand against positive identification, especially where there was no physical impossibility for petitioners to have been at the crime scene.
The Court upheld the finding of conspiracy. The acts of petitioners—collectively mauling the victim, with Maigue issuing the order to shoot and Talay executing the shooting—demonstrated a community of criminal purpose. Conspiracy having been established, all conspirators are liable as co-principals. The Court modified the penalty to an indeterminate sentence of eight years and one day of prision mayor as minimum to fourteen years, eight months, and one day of reclusion temporal as maximum, applying the Indeterminate Sentence Law. The awards of P50,000 as civil indemnity, P50,000 as moral damages, and P40,000 as actual damages to the victim’s heirs were sustained, while the deletion of exemplary damages was correct due to the absence of aggravating circumstances.