G.R. No. 149259 October 20, 2005
People of the Philippines vs. Juanito P. Quirol and Mario P. Quirol

FACTS

Appellants Juanito and Mario Quirol, along with policeman PO3 Jed Daloso (at large), were charged with double murder for the deaths of Benjamin Silva and Roel Ngujo. The incident occurred in the early morning of December 5, 1993, following a fiesta disco in Cebu City. Prosecution witness Wilson Cruz testified that after the dance, he saw Daloso stop, frisk, and handcuff the two victims. Daloso then led them towards an old airport runway, where they were met by the Quirol brothers. From a hidden vantage point, Cruz witnessed Daloso shoot Silva in the head. As Silva fell, he dragged down the handcuffed Ngujo, whom Mario then held while Juanito stabbed him with a Batangas knife; Daloso finished by shooting Ngujo. Corroborative evidence included the recovery of Juanito’s bloodstained knife.
The appellants presented contrasting defenses. Mario interposed alibi, claiming he was drunk and asleep at the dance area during the incident, a claim corroborated by a festival supervisor. Juanito admitted being at the scene but denied participation, testifying that he merely accompanied Daloso, who was taking the victims to the police station for alleged theft of his fighting cocks. Juanito claimed he fled upon hearing a gunshot without witnessing the killings.

ISSUE

Whether the guilt of appellants Juanito and Mario Quirol for the crime of double murder was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the convictions. The Court found the testimony of eyewitness Wilson Cruz credible, positive, and consistent. His account was corroborated by physical evidence, notably the bloodstained knife recovered from Juanito. The defense of alibi by Mario was correctly rejected as it was not physically impossible for him to have been at the crime scene, and it crumbled against Cruz’s positive identification. Juanito’s claim of mere presence was likewise untenable. His own testimony placed him at the scene with the victims and the principal assailant immediately before the murders. His flight and failure to report the incident, coupled with the recovery of his weapon, indicated guilt and conspiracy. The Court ruled that the killings constituted murder, qualified by treachery, as the victims were handcuffed and utterly defenseless. The penalties of reclusion perpetua for each murder were affirmed. The awards for civil indemnity and moral damages were sustained, and temperate damages were awarded in lieu of actual damages.