G.R. No. 137746 ; October 15, 2002
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REY SAN PASCUAL, SANTOS SAN PASCUAL, JR., ARNULFO BOATES, RICO BODINO, and EMILIANO BODINO (at large), accused-appellants.

FACTS

Accused-appellants Rey San Pascual, Santos San Pascual, Jr., Arnulfo Boates, Rico Bodino, and Emiliano Bodino were charged with Murder for the killing of Barangay Captain Roberto Canuel on the night of May 14, 1995, in Barangay Danao, Polangui, Albay. The prosecution’s case relied primarily on the eyewitness account of Anselmo Sidro, who testified that appellants Rey and Santos San Pascual, armed with guns, forcibly took him from his house to the victim’s residence. At the victim’s house, he saw the San Pascual brothers talking with the victim, who served them coffee. Suddenly, Rey San Pascual shot the victim, followed by several more shots. Sidro then recognized appellants Arnulfo Boates and Rico Bodino among three other persons who fled. Other witnesses corroborated parts of the event: Jesus Canuel (victim’s half-brother) testified that the San Pascual brothers, armed and accompanied by others including Arnulfo Boates, came looking for the victim earlier that night; Sonia Canuel (victim’s widow) recounted the armed group’s visit and the subsequent shooting; Wilfredo Canuel (victim’s brother) saw the appellants fleeing after hearing gunshots; and Charlie Bombase saw Rico and Emiliano Bodino arrive at a kagawad’s house shortly after the shots. Dr. Vivian Bustamante’s autopsy revealed the victim died from multiple gunshot wounds, some from behind, indicating more than one assailant. The appellants denied involvement, presenting alibis. The Regional Trial Court found them guilty of Murder and sentenced them to reclusion perpetua.

ISSUE

Whether the Regional Trial Court erred in finding accused-appellants guilty beyond reasonable doubt of the crime of Murder.

RULING

The Supreme Court affirmed the decision of the Regional Trial Court with modifications. The Court found the testimonies of the prosecution witnesses, particularly eyewitness Anselmo Sidro, to be credible, consistent, and sufficient to establish the guilt of the appellants beyond reasonable doubt. Sidro’s positive identification of the appellants, his detailed account of the events, and the corroborating testimonies of other witnesses overcame the appellants’ defenses of denial and alibi. The Court upheld the finding of conspiracy among the appellants, as their collective actions before, during, and after the shooting demonstrated a common purpose to kill the victim. The qualifying circumstance of treachery was present, as the attack was sudden and without warning, ensuring the victim had no opportunity to defend himself. The Court modified the awarded damages, increasing the civil indemnity to P75,000.00, awarding P50,000.00 as moral damages, P25,000.00 as exemplary damages, and P706,600.00 for loss of earning capacity, all with legal interest. The penalty of reclusion perpetua was affirmed.