G.R. No. 126515 . February 6, 2002.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ASSEMBLYMAN ARTURO F. PACIFICADOR (At Large), SGT. DOMINGO DALMACIO, SGT. ENRICO CABAÑERO, C2C REYNALDO ALIPALA, PFC VICENTE VEGAFRIA, P/CPL. HECTOR FULLON, and PAT. LORENZO MINGOTE, accused.

FACTS

On May 13, 1984, the eve of the Batasang Pambansa elections, a group campaigning for candidate Evelio Javier in Antique, led by NP Chairman Rhium Sanchez, was ambushed. While traversing Pangpang Bridge in Sibalom, their vehicle was blocked. Two armed men in fatigue uniforms, later identified as accused-appellants PFC Vicente Vegafria and C2C Reynaldo Alipala, approached under the pretext of an “inspection.” After they returned to their vehicles, a barrage of gunfire and explosions from both sides of the road rained on the victims’ jeep for about ten minutes. The attack resulted in the deaths of seven individuals, including Rhium Sanchez, and serious injury to Luna Sanchez, the sole surviving eyewitness.
Accused-appellants, who were military and police personnel assigned as security for incumbent Assemblyman Arturo Pacificador, were charged with multiple murder and frustrated murder. Pacificador remained at large. The trial court convicted the accused-appellants, finding their alibis weak and unsubstantiated. The court ruled that the collective testimony of the prosecution witnesses, particularly the detailed account of survivor Luna Sanchez who identified Vegafria and Alipala, established their presence and participation in the ambush beyond reasonable doubt.

ISSUE

Whether the accused-appellants are guilty beyond reasonable doubt of the crimes of multiple murder and frustrated murder.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the testimony of eyewitness Luna Sanchez credible, natural, and consistent. His positive identification of appellants Vegafria and Alipala at the scene immediately before the shooting commenced was crucial. This direct evidence convincingly established their participation. The Court rejected the appellants’ defenses of alibi and denial, which could not prevail over the positive identification by a credible witness. The alibis were not physically impossible, as the places where they claimed to be were not so far from the crime scene as to preclude their presence there.
The legal logic rests on the strength of positive identification. The Court emphasized that where there is no evidence of ill motive on the part of the eyewitness, his testimony deserves full faith and credit. The appellants’ collective actions, including the feigned inspection that immediately preceded the coordinated attack, indicated a conspiracy. All conspirators are liable as co-principals for acts done pursuant to their common design, even if the specific roles of each in the actual firing were not individually detailed. The qualifying circumstance of treachery was correctly appreciated, as the mode of attack—a sudden and overwhelming ambush from concealed positions—ensured the victims had no opportunity to defend themselves. The penalties and civil liabilities imposed by the trial court were affirmed.