G.R. No. 128378; April 30, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. ROBERT GOMEZ, JIMMY RODRIGUEZ, RENATO AMAYBAY @ BUK-AN AMAYBAY, and EDEN CARMONA, appellants.

FACTS

On November 5, 1989, in Bacolod City, eyewitness Joel Lagundino saw appellants Robert Gomez, Jimmy Rodriguez, Renato Amaybay, and Eden Carmona attack and stab Samson Perez. Lagundino, who was ten meters away under good illumination from a lamppost and a nearby store, clearly recognized the appellants as individuals he often saw in the area. He witnessed the group stabbing Perez, who managed to fire a revolver, grazing one assailant, before being overwhelmed and killed. The appellants were charged with Murder, qualified by treachery and abuse of superiority. At trial, Lagundino positively identified three appellants in court and Gomez via photograph. The defense consisted of alibis from Carmona and Amaybay, while Rodriguez claimed self-defense, alleging Perez shot at him first.

ISSUE

Whether the prosecution proved the guilt of the appellants for the crime of Murder beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the testimony of eyewitness Lagundino credible, positive, and consistent. His identification was reliable given the adequate lighting and his familiarity with the appellants, which remained unshaken during cross-examination. The claim of self-defense by Rodriguez was rejected for being inherently improbable; the number, nature, and location of the victim’s wounds, including two on the back, were inconsistent with a sudden, reflexive act of defense and instead indicated a determined attack. The collective actions of the four appellants, ganging up on a single victim, constituted abuse of superior strength, which qualified the killing to Murder. The Court modified the penalty to a single indivisible penalty of reclusion perpetua and awarded civil indemnity and moral damages to the victim’s heirs.