GR 119544; (August, 1998) (Digest)
G.R. No. 119544 August 3, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDGAR UMADHAY y TRABASAS, SERGIO UMADHAY y TRABASAS and ALBERT UMADHAY y TRABASAS, accused-appellants.
FACTS
On November 16, 1992, in Oton, Iloilo, Gonzalo “Alo” Jaranilla III was shot and killed. The prosecution’s evidence, primarily from the victim’s wife Cecilia, established that at around 10:40 p.m., she saw Albert Umadhay shoot her husband in the back with a long firearm. After Alo fell, Edgar and Sergio Umadhay, armed with short firearms, joined Albert, and all three brothers shot the victim in the head. Cecilia witnessed this from about three meters away under lighted conditions. The dying victim, while being transported to the hospital, identified his assailants as “Edgar, Sergio and Alberto all surnamed Umadhay” to witness Ricardo Suyo. The police recovered firearms based on information from the accused. Edgar admitted participation but claimed self-defense, alleging that Alo attacked him with a shotgun and a grenade, and that during a struggle for the weapons, Alo accidentally shot himself in the back and later in the head. His brothers, Albert and Sergio, denied involvement. The Regional Trial Court found all three brothers guilty of murder qualified by treachery and sentenced each to reclusion perpetua.
ISSUE
Whether the Regional Trial Court erred in convicting appellants Edgar, Sergio, and Albert Umadhay of the crime of murder.
RULING
The Supreme Court AFFIRMED the decision of the Regional Trial Court. The Court found the prosecution’s version, supported by the credible and categorical testimony of eyewitness Cecilia Jaranilla and the dying declaration of the victim, to be more credible than the appellants’ claim of self-defense and denial. The medical findings on the location and nature of the gunshot wounds corroborated the prosecution’s narrative of a concerted attack and contradicted Edgar’s story of a struggle. The positive identification by the eyewitness prevailed over the defenses of denial and alibi. The Court upheld the finding of conspiracy among the three brothers based on their coordinated actions in shooting the victim. The qualifying circumstance of treachery was properly appreciated as the attack was sudden and from behind, rendering the victim defenseless. The penalty of reclusion perpetua and the awards of civil indemnity (P50,000.00) and actual damages (P22,711.00) were affirmed.