G.R. No. 121562 July 10, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RONNIE QUITLONG y FRIAS, SALVADOR QUITLONG y FRIAS and EMILIO SENOTO, Jr., y PASCUA, accused-appellants.

FACTS

The Regional Trial Court of Baguio City convicted accused-appellants Ronnie Quitlong, Salvador Quitlong, and Emilio Senoto, Jr., of murder for the killing of Jonathan Calpito and sentenced each to an indeterminate penalty. The case originated from an incident on October 20, 1994. The victim, Jonathan Calpito, after playing billiards and attempting to go home, argued with a fishball vendor over change. Herbert Soriano, driving a jeep, offered Calpito and his friends a ride. Moments later, Soriano saw eight men rush towards Calpito and his friend. Prosecution witness Lito Adjaro saw appellants Emilio Senoto embrace Calpito from behind while appellants Salvador and Ronnie Quitlong held Calpito’s right and left hands, respectively. Ronnie Quitlong then stabbed Calpito on the left side below the nipple. After Calpito fell, his assailants continued to hit him. Police officers on patrol arrived, and the assailants fled. Calpito was rushed to the hospital but died that evening from a stab wound that penetrated his heart. The defense admitted appellants’ presence at the scene but denied participation, claiming it was a certain Jesus Mendoza who stabbed the victim after being irked when the victim urinated near his wife. Defense witnesses Nonita de los Reyes and Lydia Cultura corroborated this story. The amended information included Jesus Mendoza, who remained at large.

ISSUE

The primary issue is whether the trial court erred in finding accused-appellants guilty of murder based on conspiracy, despite the defense’s claim that Jesus Mendoza was the sole perpetrator.

RULING

The Supreme Court affirmed the conviction but modified the penalties and damages. It held that conspiracy was sufficiently established by the appellants’ collective and coordinated actions in holding the victim, enabling the stabbing. The defense of denial could not prevail over the positive identification by prosecution witnesses. The killing was qualified by treachery (alevosia) as the attack was sudden and unexpected, rendering the victim defenseless. The Court found appellants guilty as principals by direct participation. The penalty was modified to reclusion perpetua. The indemnity for death was increased to P50,000.00, moral damages to P50,000.00, and exemplary damages of P25,000.00 were awarded. The award for consequential damages was deleted for lack of substantiation. Appellants were held solidarily liable for the damages.