G.R. No. 175835; July 13, 2010
PEOPLE OF THE PHILIPPINES, Appellee, vs. GERARDO ROLLAN y REY, Appellant.
FACTS
The prosecution charged Gerardo Rollan and several others with the murder of Rolando Yrigan. Two eyewitnesses, Alfredo Monsanto and his son Allan, testified to the killing. Alfredo stated that on November 23, 1995, he saw a group of men, including Rollan, attack Yrigan. He testified that Renato dela Cruz and Tomtom Benoza held Yrigan’s hands, while Rollan and others took turns stabbing him with a long bladed weapon. Allan Monsanto testified that he saw Yrigan being attacked by seven men. He claimed that Rollan and Melo Benabesi were the ones holding Yrigan’s hands, while Dela Cruz and others stabbed him. The autopsy confirmed Yrigan died from traumatic head injury and stab wounds. Rollan interposed an alibi, claiming he was driving his jeepney route at the time.
The Regional Trial Court convicted Rollan, Dela Cruz, and Benabesi of murder. Upon motion, the RTC acquitted Benabesi, citing inconsistencies in the eyewitness accounts regarding his specific role. Rollan appealed, arguing the contradictory testimonies of Alfredo and Allan created reasonable doubt. The Court of Appeals affirmed his conviction, leading to this appeal.
ISSUE
Whether the Court of Appeals erred in affirming Rollan’s conviction despite alleged inconsistencies in the eyewitness testimonies.
RULING
The Supreme Court affirmed the conviction. The apparent inconsistency between the two eyewitnesses—specifically regarding which individuals held the victim’s hands and which inflicted the stab wounds—does not destroy their credibility nor negate the existence of conspiracy. The Court emphasized that minor discrepancies in details are common and even indicative of truthful, unrehearsed testimony. Both witnesses consistently identified Rollan as a direct participant in the concerted attack. Their testimonies were credible as they were neighbors who knew the accused and had no ill motive to falsely testify. The autopsy report corroborated their collective account of a violent group assault.
The legal logic centers on the principle of conspiracy. When conspiracy is established, as it was here through the witnesses’ accounts of simultaneous, coordinated actions to immobilize and kill the victim, the precise individual role of each conspirator becomes secondary. All conspirators are liable for the acts of the others in furtherance of the common design. Therefore, whether Rollan was specifically holding the victim or directly stabbing him, his presence and participation in the concerted attack rendered him equally guilty of murder. The alibi was correctly rejected for being weak and unsubstantiated.