GR 130931; (May, 1999) (Digest)
G.R. No. 130931 May 19, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ERICK MACAHIA, REDENTOR MACAHIA and REYNALDO MACAHIA, accused, ERICK MACAHIA and REDENTOR MACAHIA, appellants.
FACTS
The prosecution’s case, primarily through eyewitness Loven Magtibay, established that on September 12, 1994, in Quezon City, appellants Erick and Redentor Macahia, along with their brother Reynaldo (at large), conspired to kill Cenon Gonzales. Erick and Redentor first inquired about Gonzales’s whereabouts before trailing him. As Gonzales passed a parked jeepney, the three brothers simultaneously grabbed him by the neck, thighs, and body. Erick, holding Gonzales’s neck, then pulled out a gun and shot him in the head at close range. Gonzales died from the gunshot wound. The defense of appellants Erick and Redentor was alibi and denial, claiming they were in Tanauan, Batangas, celebrating their parents’ wedding anniversary at the time of the crime. They were supported by testimonies from their father and a provincemate.
ISSUE
The core issue is whether the prosecution proved the guilt of appellants Erick and Redentor Macahia for the crime of Murder beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, giving great weight to Loven Magtibay’s positive identification of the appellants as the perpetrators. His testimony was clear, consistent, and credible despite minor inconsistencies, which were deemed natural for a witness recounting a traumatic event. His account was corroborated by the medico-legal findings, which indicated the victim was shot from behind at close range, supporting the manner of attack described. The defense of alibi was correctly rejected as it was not physically impossible for the appellants to have been at the crime scene, and it was inherently weak against Magtibay’s positive identification. The Court found that the killing was attended by treachery (alevosia). The attack was sudden and from behind, ensuring the victim had no opportunity to defend himself or retaliate, qualifying the homicide as Murder. Furthermore, the appellants’ concerted actions in holding the victim down before the shooting demonstrated a community of criminal purpose, establishing conspiracy. Thus, all were equally liable as co-principals. The penalty of reclusion perpetua and the awarded damages were affirmed.