GR 134938; (June, 2000) (Digest)
G.R. No. 134938; June 8, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CARLOS FORCA (at large), RUFINO TESTON and ROGELIO GACO, accused, RUFINO TESTON and ROGELIO GACO, accused-appellants.
FACTS
Accused-appellants Rufino Teston and Rogelio Gaco, along with Carlos Forca and Manuel Osorio, were charged with the murder of Vladiner Decena. The prosecution alleged that on April 14, 1995, in Barangay Sowangan, Quezon, Palawan, the accused, armed with bladed weapons, conspired to attack, stab, and hack Decena, causing his death. Eyewitness Victor Bucol testified that after a brief altercation between Forca and the victim, Forca initiated the attack by stabbing Decena. Bucol claimed that Gaco and Osorio then held the victim, enabling Forca to stab him further, after which Teston hacked the victim multiple times. The defense, primarily through the testimony of discharged state witness Osorio, presented a different version, claiming the victim had first fired a gun at Forca and Teston, and they attacked in self-defense. Alex Inaje also testified for the prosecution about a prior conspiracy among the accused to kill a member of the Decena family.
ISSUE
The core issue is whether the guilt of accused-appellants Rufino Teston and Rogelio Gaco for the crime of murder was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court found the testimony of prosecution eyewitness Victor Bucol to be credible, consistent, and corroborated by the physical evidence, particularly the autopsy report detailing fourteen hacking and stab wounds. The Court rejected the defense of self-defense invoked through Osorio’s testimony, as it was inherently improbable and unsupported. The number, location, and severity of the wounds inflicted were indicative of a determined effort to kill, negating any claim of necessary self-defense. The Court upheld the finding of conspiracy based on the coordinated actions of the accused during the attack, as established by Bucol’s account. The qualifying circumstance of treachery was correctly appreciated because the initial sudden stabbing by Forca, followed by the collective restraint and assault by the group, ensured the victim had no opportunity to defend himself. Abuse of superior strength was absorbed in treachery. The Court modified the penalty to reclusion perpetua, as the death penalty was not yet in effect at the time of the crime, and awarded civil indemnity to the victim’s heirs.