G.R. No. 131841; October 23, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RUBEN VILLARMOSA, ANTHONY EBIDO, and MARCELINO EBIDO, accused-appellants.

FACTS

The accused-appellants were charged with the murder of Dioscoro Oasnon. The prosecution presented eyewitness Rodrigo Oronan, who testified that on the evening of July 12, 1995, while he and the victim were at a store, Ruben Villarmosa suddenly stabbed Oasnon with a fan knife. Anthony Ebido then hacked the victim on the head, and Marcelino Ebido struck him with an iron pipe. The autopsy report confirmed the victim died from multiple stab and hacking wounds. Vicente Nebiar, a defense witness present at the store, corroborated the suddenness of the attack, hearing a shout that the victim had fallen shortly after the appellants left their drinking session.
The defense, however, presented a version of self-defense. Ruben Villarmosa and Anthony Ebido claimed they were attacked by two masked men, one of whom was the victim, who allegedly pointed a gun at Ruben. They asserted they retaliated to defend themselves. Marcelino Ebido denied any participation. The trial court rejected this narrative, convicted all three of murder qualified by treachery, and sentenced them to reclusion perpetua.

ISSUE

The core issues were: (1) whether the killing was attended by treachery to qualify it as murder, and (2) whether Marcelino Ebido’s guilt was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction for murder but modified the damages. The Court upheld the trial court’s assessment of witness credibility, finding the prosecution’s eyewitness account clear and consistent. The claim of self-defense by Villarmosa and Anthony Ebido was rejected for being inherently improbable and unsupported by evidence; the nature, number, and location of the victim’s wounds were inconsistent with a spontaneous, defensive reaction. The Court found treachery present because the attack was sudden and unexpected, depriving the unarmed victim of any chance to defend himself. This manner of execution ensured the assailants’ safety from any retaliation.
Regarding Marcelino Ebido, the Court found his conspiracy and participation duly established by the eyewitness who positively identified him as having struck the victim with an iron pipe. His presence and actions, in concert with the other appellants, demonstrated a community of criminal purpose. The penalty of reclusion perpetua was affirmed. The Court recalculated the civil liabilities, reducing the actual damages to the amount supported by receipts (P10,660) and awarding loss of earning capacity (P1,043,898.81) and civil indemnity (P50,000).