GR 141518; (April, 2003) (Digest)
G.R. No. 141518; April 29, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. CLARENCE ASTUDILLO, CRISANTO ASTUDILLO, alias “ANTENG” or “ENTENG”, HILARIO ASTUDILLO, alias “BODA”, appellant.
FACTS
The prosecution’s evidence established that on November 12, 1995, appellants Clarence, Crisanto, and Hilario Astudillo invited the victim, Silvestre Aquino, Jr., to a store. An argument ensued between Crisanto and Silvestre. Eyewitnesses, two young boys selling balut, testified that they saw Clarence stab Silvestre with a bolo while Crisanto and Hilario held the victim by his wrists. Clarence delivered multiple stab blows until Silvestre fell. The appellants then fled on a tricycle. The victim sustained fifteen stab wounds and died from cardiac tamponade.
The defense presented a different narrative, claiming self-defense. Clarence alleged that Silvestre attacked him with a bottle after being embarrassed. Hilario testified that he intervened, picked up a knife, and stabbed the advancing victim two or three times in defense. The appellants surrendered to the police on the same night. The trial court convicted them of Murder.
ISSUE
The core issues were: (1) whether the prosecution proved the guilt of the appellants beyond reasonable doubt, and (2) whether the crime was properly qualified as Murder.
RULING
The Supreme Court affirmed the conviction for Murder. On the first issue, the Court found the testimonies of the young prosecution eyewitnesses credible and consistent. Their positive identification of the appellants and detailed account of the concerted attack prevailed over the appellants’ claim of self-defense, which was unsupported by evidence of unlawful aggression on the part of the victim. The nature, number, and location of the wounds negated self-defense and indicated a determined effort to kill.
On the second issue, the Court ruled that treachery qualified the killing to Murder. The Information specifically alleged treachery. The evidence showed that the attack was sudden and deliberate. The act of two brothers holding the victim by his wrists rendered him defenseless against the fatal stabbing by the third, ensuring the execution of the attack without risk to the appellants. This manner of execution directly and specifically showed how treachery attended the commission of the crime. The Court modified the awarded damages but sustained the penalty of reclusion perpetua.