G.R. No. 121897 ; August 16, 2001
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GIL TEMPLA alias “GEORGE,” EMMANUEL ALAGON alias “AWE,” and FLORIANO JUNGAO alias “ANOY”, defendant-appellants.

FACTS

In the early morning of October 28, 1988, in Guiwanon, Baclayon, Bohol, 11-year-old Pompeo Alo and his sister Ferlina were awakened by a loud noise. Looking through their window, they saw appellants Templa, Jungao, and Alagon, along with others, in their yard. By the moonlight, they witnessed an altercation where Templa and Jungao successively beat the victim, Isaias “Sonny Boy” Lagura, with pieces of wood, while Alagon threw a stone at him, causing him to fall. After a brief interval, the appellants threw more stones at the victim as he walked away. The victim initially downplayed his injuries when questioned by his brother later that morning but eventually named the appellants as his assailants. He collapsed on November 2, 1988, was hospitalized, and died the following day. An Information for Murder was filed against the appellants.

ISSUE

The core issue is whether the prosecution established the guilt of appellants Templa, Jungao, and Alagon for the crime of Murder beyond reasonable doubt, particularly challenging the credibility of the eyewitness account and the existence of conspiracy.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the credibility of prosecution witness Pompeo Alo. His testimony was found to be clear, consistent, and replete with details, and it was corroborated by the medical findings which revealed fatal injuries consistent with being hit by solid objects. The appellants’ claim of self-defense by Templa was rejected for being uncorroborated and incompatible with the evidence showing a concerted attack. The Court found conspiracy among the appellants, as their individual acts of beating and stoning the victim demonstrated a unity of purpose to inflict harm. With conspiracy established, all conspirators are liable as co-principals. The qualifying circumstance of abuse of superior strength was correctly appreciated, as the three appellants, armed with wood and stones, collectively assaulted a single, unarmed victim. The crime is Murder, punishable by reclusion perpetua to death. Applying Article 63 of the Revised Penal Code and considering the prohibition against imposing the death penalty for crimes committed before the effectivity of Republic Act No. 7659 , the proper penalty is reclusion perpetua. The civil awards were modified, with the P50,000 moral damages properly designated as civil indemnity, and all liabilities were declared joint and solidary.