GR 174483; (March, 2009) (Digest)
G.R. No. 174483 March 31, 2009
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RAMON REGALARIO, MARCIANO REGALARIO, SOTERO REGALARIO, BIENVENIDO REGALARIO and NOEL REGALARIO, Accused-Appellants.
FACTS
Accused-appellants, all surnamed Regalario, were barangay officials of Natasan, Libon, Albay, related by consanguinity. They were charged with Murder for the death of Rolando Sevilla on February 22, 1997. The prosecution evidence established that during a barangay dance, a commotion ensued. Accused Sotero and Bienvenido struck the victim with nightsticks (bahi). The victim ran towards the house of barangay captain Marciano Regalario, where he was waylaid by Ramon Regalario. Marciano and his son Noel then came out, with Noel carrying a knife. The five accused caught the victim, took turns hitting him with nightsticks until he slumped face down, after which Marciano boxed him. Marciano then ordered the others to kill and tie up the victim. Bienvenido, with Sotero’s help, tied the victim’s neck, hands, and feet with a nylon rope. The victim’s body was found tied up. The autopsy revealed multiple lacerated wounds, stab wounds, contusions, and hematoma, with cause of death being severe blood loss. The accused raised the defense of denial, except for Ramon who claimed self-defense. The Regional Trial Court found them guilty of Murder qualified by abuse of superior strength and scoffing at the corpse, with the mitigating circumstance of voluntary surrender, and sentenced them to reclusion perpetua. The Court of Appeals affirmed the conviction with modifications to the damages. The case was elevated to the Supreme Court for automatic review.
ISSUE
The main issue is whether the accused-appellants are guilty of the crime of Murder.
RULING
The Supreme Court affirmed the conviction. It held that the prosecution proved the guilt of the accused-appellants beyond reasonable doubt. The Court found conspiracy among the accused, as their collective actions showed a unity of purpose to kill the victim. The killing was qualified by abuse of superior strength, as the five armed accused jointly assaulted a single, unarmed victim. The Court rejected Ramon Regalario’s claim of self-defense for being uncorroborated and inconsistent with the physical evidence. The Court also affirmed the presence of the mitigating circumstance of voluntary surrender. The penalty of reclusion perpetua was imposed, as the death penalty was prohibited at the time of the decision. The Court modified the awarded damages: civil indemnity was increased to ₱75,000.00, moral damages to ₱75,000.00, exemplary damages of ₱30,000.00 were awarded, and temperate damages of ₱25,000.00 were awarded in lieu of actual damages, all with legal interest.