GR 121201; (October, 2001) (Digest)
G.R. Nos. 121201-02; October 19, 2001
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GIO CONCORCIO @ JUN, EDWIN YUNGOT, ROMMEL MAGPATOC and JOSEL AYALA @ DODONG LANAY, accused. EDWIN YUNGOT and ROMMEL MAGPATOC, accused-appellants.
FACTS
On May 24, 1987, in Davao City, Jernie Sumagaysay and Oscar Celis were stabbed to death. Accused-appellants Edwin Yungot and Rommel Magpatoc, along with two others who remained at large, were charged with two counts of murder. The prosecution’s case primarily rested on the testimonies of eyewitness Jose Lagamon, Jr. and self-confessed participant Jonathan Abellana. Lagamon testified that he saw Yungot stab Celis and another person, later identified as Magpatoc, stab Sumagaysay. Abellana, who was serving a sentence for another murder, testified that he was part of the group with the appellants and detailed their conspiracy to commit the killings.
The defense presented alibis. Yungot claimed he was at a different location, while Magpatoc asserted he was at home. They attacked the credibility of the prosecution witnesses, arguing that Lagamon failed to report the incident immediately and that Abellana was a convicted felon whose testimony was unreliable. The trial court convicted Yungot and Magpatoc of two counts of murder, qualified by treachery, and sentenced each to two terms of reclusion perpetua. They appealed.
ISSUE
The core issue is whether the prosecution proved the guilt of accused-appellants Edwin Yungot and Rommel Magpatoc beyond reasonable doubt for the crime of murder.
RULING
The Supreme Court affirmed the convictions. The Court found the testimonies of prosecution witnesses credible and sufficient to establish guilt. Jose Lagamon, Jr. was a credible eyewitness; his proximity to the crime scene and the adequate lighting allowed for a clear view, and his failure to report immediately did not undermine his positive identification. The testimony of Jonathan Abellana, despite his criminal record, was corroborated on material points and provided crucial details on the appellants’ conspiracy and direct participation. The Court held that the defense of alibi must fail as it cannot prevail over the positive identification by credible witnesses. The appellants’ alibis were not physically impossible and were weakly corroborated.
The killings were correctly qualified as murder due to the presence of treachery. The attack was sudden and unexpected, depriving the unarmed victims of any chance to defend themselves. The Court also upheld the finding of conspiracy, as the appellants’ coordinated actions in simultaneously attacking the two victims demonstrated a common criminal purpose. All conspirators are liable as principals. The penalties of reclusion perpetua for each count were affirmed, with modifications to the awarded damages.