GR 128886; (November, 2001) (Digest)
G.R. No. 128886; November 23, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JESUS JULIANDA, JR. and SAMSON GUERRERO, accused-appellants.
FACTS
On January 15, 1994, in Barangay Along-ong, Libon, Albay, brothers Teofilo and Ferdinand Coralde were ambushed by a group of armed men. Teofilo, initially riding a carabao, was blocked by the Julianda brothers. He and Ferdinand sought refuge in a nearby store but were followed and surrounded by approximately twenty individuals, including appellants Jesus Julianda, Jr. and Samson Guerrero. The group dragged Teofilo out, where he was hacked, stoned, and beaten with a lead pipe, resulting in his death from multiple stab wounds. Ferdinand, who attempted to aid his brother, was also attacked, struck with a stone by Guerrero, and ganged upon, sustaining injuries before managing to escape.
Two informations for Murder and Attempted Murder were filed against seven accused. Only appellants Jesus Julianda, Jr. and Samson Guerrero were arrested and stood trial. The prosecution presented eyewitnesses, including Gertrudes Casalo and the surviving victim Ferdinand Coralde, who positively identified the appellants as participants in the concerted attack. The defense consisted of denial and alibi, claiming they were elsewhere during the incident.
ISSUE
The core issue is whether the guilt of appellants Jesus Julianda, Jr. and Samson Guerrero for the crimes of Murder and Attempted Murder was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the convictions. The Court found the testimonies of the prosecution eyewitnesses credible, consistent, and sufficient to establish the appellants’ participation. The witnesses had a clear view of the incident and positively identified Julianda, Jr. as one who stoned the victim and Guerrero as one who struck both victims with a stone and a lead pipe. Their collective actions demonstrated a community of criminal purpose, establishing conspiracy. When conspiracy is proven, the act of one is the act of all, rendering each co-conspirator liable for the resulting crimes.
The qualifying circumstance of treachery was correctly appreciated for the Murder charge. The attack was sudden and deliberate, employing overwhelming force that rendered Teofilo defenseless from the outset, ensuring the execution of the assault without risk to the assailants. For Attempted Murder against Ferdinand, the essence of the ruling is that the appellants commenced the commission of the felony by overt acts but did not consummate it due to the victim’s escape, a reason independent of their will. The Court modified the awarded damages, reducing unsubstantiated actual damages and awarding civil indemnity and moral damages in accordance with prevailing jurisprudence.