G.R. No. 120550 September 26, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTOLIN HAYAHAY, ET AL., accused-appellants.

FACTS

The accused-appellants were convicted of murder for the killing of Gorgonio Lapu-Lapu. The prosecution’s case rested primarily on the eyewitness account of Ramil Lapu-Lapu, the victim’s brother. He testified that on the evening of November 2, 1990, he and Gorgonio were accosted by the eight appellants. Edito Comedia stabbed Gorgonio in the chest, while Antolin Hayahay and Orlando Licanda stabbed him in the back. Dionisio Olasiman clubbed him with an iron bar, Serafin Moreles hit him with wood, and Miliano Olasiman and Zaldy Billentes boxed and kicked him. Ramil, who was five meters away, clearly identified all assailants under the illumination of a full moon and nearby kerosene lamps. He fled but returned to find his brother, who died moments later. The autopsy revealed eleven stab wounds, four of which were fatal.
The appellants interposed the defenses of denial and alibi. Hayahay claimed he was upstairs in a neighbor’s gambling house during the incident and did not see the assailants. Comedia alleged he was working as a jeepney conductor seven kilometers away. Miliano Olasiman stated he was at home fifty meters from the scene. They collectively asserted that they were later arrested and, in some cases, coerced into confessing by the police.

ISSUE

Whether the trial court correctly convicted the accused-appellants of murder based on the prosecution’s evidence.

RULING

Yes, the Supreme Court affirmed the conviction. The positive identification by eyewitness Ramil Lapu-Lapu, who had no ill motive to falsely testify, prevailed over the weak defenses of denial and alibi. The Court found Ramil’s testimony credible, consistent, and corroborated by the physical evidence. His proximity to the event, adequate lighting, and familiarity with the appellants established the reliability of his account. The defenses of alibi failed as the appellants did not prove it was physically impossible for them to be at the crime scene. For instance, Comedia’s claimed location was only seven kilometers away, not an insurmountable distance.
The qualifying circumstances of treachery and abuse of superior strength were correctly appreciated. The attack was sudden and unprovoked, rendering the unarmed victim defenseless. The concerted action of eight assailants, five of whom were armed with deadly weapons against a single victim, constituted notorious inequality of force. This mode of attack ensured the execution of the crime without risk to the appellants arising from any defense the victim could make. Thus, the crime was properly qualified as murder.