GR 175881; (August, 2007) (Digest)
G.R. No. 175881 ; August 28, 2007
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ARMANDO RODAS and JOSE RODAS, SR., Accused-Appellants.
FACTS
Accused-appellants Armando Rodas and Jose Rodas, Sr., along with Charlito Rodas and Jose Rodas, Jr., were charged with Murder for the killing of Titing Asenda on August 9, 1996. The prosecution alleged that during a benefit dance, the four accused surrounded the victim. Charlito stabbed him, Armando clubbed him with a chako, and Jose Jr. hacked him with a bolo handed by Jose Sr. Eyewitnesses Alberto Asonda and Ernie Anggot testified to this sequence. During trial, Charlito and Jose Jr. pleaded guilty to the lesser crime of Homicide and were sentenced accordingly.
The defense presented a different account. Armando and Jose Sr. denied participation, asserting they were not at the scene. Jose Sr. claimed he was at home and later brought Charlito to surrender. Armando similarly alleged he was asleep at home. Vilma Rodas, Armando’s wife, testified only Charlito and Jose Jr. were involved. The Regional Trial Court convicted Armando and Jose Sr. of Murder, sentencing them to reclusion perpetua. The Court of Appeals affirmed the conviction.
ISSUE
Whether the guilt of accused-appellants Armando Rodas and Jose Rodas, Sr., for the crime of Murder was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment crediting the positive, categorical, and consistent testimonies of eyewitnesses Asonda and Anggot. They clearly detailed how all four accused, acting in concert, attacked the victim suddenly and without warning. This collective action established conspiracy, rendering each co-conspirator equally liable for the acts of the others. The manner of attack—sudden, synchronized, and from different sides—ensured the victim had no opportunity to defend himself, qualifying the killing with treachery.
The defense of alibi and denial was correctly rejected. For alibi to prosper, accused must demonstrate it was physically impossible for them to be at the crime scene. Appellants failed to do so. Their bare denial cannot prevail over the positive identification by credible witnesses. The guilty pleas of their co-accused, Charlito and Jose Jr., do not exonerate appellants, as conspiracy makes the act of one the act of all. The Court found no reason to disturb the factual findings of the lower courts, which are accorded high respect. The penalty of reclusion perpetua and awarded damages were affirmed.