G.R. No. 171017 ; December 6, 2006
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ZOSIMO AGUILA y ATIENZA, accused-appellant.

FACTS

Accused-appellant Zosimo Aguila was charged with murder for the killing of Conrado Enriquez. The prosecution evidence established that on the evening of September 3, 2000, the victim, Conrado, was heavily intoxicated and asleep on a bench at a waiting shed after attending a birthday party. Witness Simplicio Manalo, who was waiting for a ride, saw appellant and Ronilo Bautista approach the sleeping victim. Despite Manalo’s advice not to disturb Conrado, appellant and Ronilo woke him, placed his arms around their shoulders, and led him towards a vacant lot. Shortly after, Manalo heard cracking sounds and shouts from that direction and saw two persons assaulting Conrado, whom he identified as appellant and Ronilo. The victim’s body was discovered the next day with fatal head injuries.
Donald Enriquez, the victim’s brother, corroborated part of the incident, testifying that he saw appellant and Ronilo at the party and later walking towards the waiting shed where Conrado was sleeping. Dr. Corazon Sabile, the medico-legal officer, confirmed the cause of death was multiple head injuries consistent with being struck by a blunt object like a piece of wood. The defense, primarily relying on denial and alibi, claimed appellant was elsewhere at the time.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for the crime of murder beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court found the testimonies of prosecution witnesses, particularly Simplicio Manalo, to be credible, consistent, and sufficient to establish appellant’s guilt. Manalo’s account was deemed credible as he had no motive to falsely testify and his narration was straightforward. His initial reluctance to come forward was reasonably explained by fear for his safety. The Court rejected the defense of denial and alibi as weak and unsubstantiated, especially since the defense failed to prove it was physically impossible for appellant to have been at the crime scene.
Regarding the qualifying circumstance, the Court upheld the finding of treachery. The attack was sudden and without warning, executed against a victim who was heavily drunk and asleep, rendering him utterly defenseless. This method ensured the execution of the crime without risk to the assailant. The Court modified the damages awarded by the lower courts, adding exemplary damages of P25,000.00 because the crime was committed with a qualifying aggravating circumstance. The penalty of reclusion perpetua and other awarded damages for civil indemnity, moral damages, and actual expenses were affirmed.