GR 135551; (October, 2000) (Digest)
G.R. No. 135551; October 27, 2000
People of the Philippines, plaintiff-appellee, vs. Ampie Taraya y Cantuba @ “Boyet,” Arly Cantuba y Daigo @ “Beget” and Jonar Estrada y Cantuba, accused-appellants.
FACTS
Accused-appellants Ampie Taraya, Arly Cantuba, and Jonar Estrada were charged with Murder for the killing of Salvador Reyes on September 24, 1995, in Famy, Laguna. The prosecution presented eyewitness David Angeles, Jr., who testified that while outside his house at night, he saw Ampie approach the victim, who appeared to be urinating, hold up his head, and slash his neck once with a bolo. David claimed Arly and Jonar were standing nearby, ready to assist Ampie. After the attack, all three accused fled. The victim’s father also testified about a prior altercation between the victim and Arly. The defense presented alibis, denying involvement and suggesting the eyewitness testimony was motivated by a prior grudge stemming from a fight between the witness’s brother and Jonar.
ISSUE
The primary issue is whether the prosecution proved the guilt of all three accused beyond reasonable doubt for the crime of Murder, including the existence of conspiracy and the qualifying circumstance of treachery.
RULING
The Supreme Court modified the trial court’s decision. It affirmed the conviction of Ampie Taraya but only for Homicide, not Murder, and acquitted Arly Cantuba and Jonar Estrada on grounds of reasonable doubt. The Court found the testimony of eyewitness David Angeles credible, straightforward, and consistent, establishing that Ampie was the sole direct perpetrator of the fatal hacking. However, the evidence failed to prove conspiracy among the three accused. The mere presence of Arly and Jonar at the scene, without clear proof of a prior agreement or concerted action to commit the crime, was insufficient to establish conspiracy. Their alleged act of being “ready to assist” was deemed vague and did not constitute direct participation or indispensable cooperation.
Furthermore, the qualifying circumstance of treachery was not proven. The prosecution did not establish how the attack was commenced, and the eyewitness account indicated the victim was possibly in a vulnerable position while urinating, but the exact manner of assault was not detailed to show the deliberate adoption of means ensuring the victim’s defenselessness. Consequently, without treachery or conspiracy, the crime committed by Ampie was Homicide. He was sentenced to an indeterminate penalty and ordered to pay civil indemnity. Arly and Jonar were ordered released due to the prosecution’s failure to prove their guilt beyond reasonable doubt.