G.R. No. 137518 ; March 6, 2002
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDITHO SUYUM and PEDRO OCANIA, accused-appellants.

FACTS

Accused-appellants Editho Suyum and Pedro Ocania were charged with the murder of Rommel Ampo on January 12, 1997, in Parañaque. The prosecution presented eyewitnesses Edgar Luid and Darlindo Coyno, who testified that they saw the appellants attack Ampo. Luid stated that while he and the victim were drinking, Suyum, armed with a bolo, approached. Luid fled but later saw Ocania holding Ampo’s hands from behind while Suyum hacked him on the neck and stabbed him in the shoulder. Coyno corroborated this, adding that Suyum marked an “x” on the victim’s face with the bolo. The victim’s sister, Glenda Ampo, also testified, stating she met Suyum carrying a bloodied weapon. The autopsy report indicated six incised wounds on the face and a fatal stab wound on the chest.
The defense presented a different version, claiming self-defense. Suyum testified that after a drinking session, an argument ensued, and Ampo left and returned with a bolo, stabbing Ocania first. A struggle for the weapon followed, during which Ampo slipped and was accidentally stabbed. Ocania corroborated this, stating he was wounded and ran away. The defense also presented other witnesses to support their account.

ISSUE

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

RULING

Yes, the Supreme Court affirmed the conviction for murder but modified the penalty to reclusion perpetua. The Court found the testimonies of prosecution eyewitnesses Luid and Coyno to be credible, consistent, and corroborated by physical evidence. Their positive identification of the appellants as the perpetrators was deemed reliable. The defense of self-defense and accident was rejected for being inherently improbable and unsupported by evidence. The nature, number, and location of the wounds—including the fatal stab wound and the deliberate “x” mark—were inconsistent with a sudden, accidental encounter and instead indicated a determined attack. The Court ruled that treachery attended the killing, qualifying it as murder, as the attack was sudden and rendered the victim defenseless, particularly when he was allegedly held by Ocania. However, the death penalty was reduced to reclusion perpetua as no aggravating circumstances were proven. The awards for damages were also modified, with civil indemnity and moral damages set at P50,000 each, and actual damages reduced to P12,500, while exemplary damages were deleted.