G.R. No. 132784; October 30, 2000
The People of the Philippines, plaintiff-appellee, vs. Leonilo Villarba y Bautista, Wilfredo Maggay Saquing, and Peter Maggay y Flordeliz, accused-appellants.

FACTS

Accused-appellants Leonilo Villarba, Wilfredo Maggay, and Peter Maggay were charged with the murder of tricycle driver Moises Pascua on March 12, 1995, in Pateros, Metro Manila. The prosecution presented two eyewitnesses. Reynaldo Pascua, the victim’s cousin, testified that while he and the victim were driving their tricycles, appellants blocked their path. Wilfredo and Peter held the tricycle, and Leonilo stabbed Moises several times with a bayonet. Rolando Membrera, another eyewitness, corroborated this, detailing how all three appellants actively participated in the attack using a bayonet, a fan knife, and a metal-tipped wooden bar.
The defense interposed denial and claimed self-defense. Leonilo Villarba admitted stabbing the victim but asserted he did so to defend his grandson, Peter, who was allegedly being chased by an armed Moises Pascua. Peter and Wilfredo claimed they were not at the scene, stating that a mob later gathered outside their house. The Regional Trial Court convicted all three of murder qualified by treachery and sentenced them to reclusion perpetua.

ISSUE

Whether the guilt of accused-appellants for the crime of murder was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The positive and categorical identification by two credible eyewitnesses, who had no ill motive to testify falsely, prevailed over the appellants’ defenses of denial and self-defense. The Court found the testimonies of Reynaldo Pascua and Rolando Membrera clear, consistent, and convincing in establishing a concerted attack by all three appellants. The claim of self-defense by Leonilo Villarba failed because he did not prove the essential elements of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. His admission of stabbing the victim, coupled with the autopsy report showing multiple fatal wounds, was incompatible with a claim of mere defense.
The Court also upheld the finding of treachery (alevosia). The attack was sudden and deliberate, executed in a manner that deprived the unarmed victim of any opportunity to defend himself or retaliate, ensuring the execution of the crime without risk to the appellants. The mitigating circumstance of minority was applied in favor of Peter Maggay, who was 16 years old at the time of the commission of the crime. Consequently, his penalty was reduced, and he was entitled to the privileged mitigating circumstance under the Revised Penal Code. The awards for civil indemnity and damages were affirmed with modification.