GR 120394; (January, 2001) (Digest)
G.R. No. 120394 -97, January 16, 2001
People of the Philippines vs. Danilo Pablo y Malunes, Nicolas Compra y Fernandez, and Edwin Trabuncon y Gatague
FACTS
Accused-appellants Danilo Pablo, Nicolas Compra, and Edwin Trabuncon were convicted by the Regional Trial Court of three counts of murder and one count of attempted murder. The charges stemmed from a single incident on March 8, 1992, in Quezon City. The prosecution evidence established that a group, including the appellants and led by Renato “Panong” Danao, arrived at the Loveres residence. Panong demanded that a “troublemaker” be brought out, and when Lucita Loveres replied there was none, Panong shot her. Her son, Edgar Loveres, was then stabbed and hit with a piece of wood as he tried to aid her. Subsequently, Lucita’s husband, Domingo, and another son, Robert, were dragged to a nearby house where the group, with appellants’ active participation, stabbed and hacked them to death.
ISSUE
The core issue on appeal was whether the prosecution proved the guilt of the appellants beyond reasonable doubt, particularly in light of their defenses of denial and alibi, and whether the qualifying circumstances of treachery and conspiracy were correctly appreciated.
RULING
The Supreme Court affirmed the convictions. The Court found the testimonies of eyewitnesses Edgar and Jocelyn Loveres to be credible, consistent, and positive in identifying the appellants’ direct participation in the attacks. Their declarations were corroborated by medical evidence and the physical circumstances of the crime scene, which was illuminated by a fluorescent light, enabling clear identification. The defenses of denial and alibi were correctly rejected by the trial court. Alibi is inherently weak and cannot prevail over positive identification, especially when the appellants failed to prove it was physically impossible for them to have been at the crime scene.
The Court upheld the finding of conspiracy. The appellants acted in concert with a common purpose to attack the victims, as demonstrated by their collective and simultaneous actions—arming themselves, surrounding the victims, and jointly executing the assaults. This collective responsibility meant each appellant was liable for the acts of the others. Treachery was properly appreciated for the three murders. The attack on the unarmed Domingo and Robert, who were forcibly dragged and then collectively assaulted, ensured their defenselessness. The sudden and unexpected shooting of Lucita, who was merely conversing, also constituted treachery. For the attempted murder of Edgar, treachery was not alleged in the Information and thus could not be considered, but his wounding by multiple assailants as part of the concerted attack sustained the conviction. The penalties imposed by the trial court were affirmed.