G.R. No. 184792 ; October 12, 2009
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ALFREDO DELA CRUZ y MIRANDA, alias “DIDONG,” Accused-Appellant.

FACTS

Accused-appellant Alfredo Dela Cruz, along with three others, was charged with the murder of Ahlladin Trinidad on November 20, 2001, in San Rafael, Bulacan. The prosecution’s case primarily rested on the testimonies of eyewitness Anthony Villacorta, then 13 years old, and his mother, Zenaida Soriano. Anthony initially gave a statement implicating only three co-accused, describing a drinking session he witnessed, after which he saw the victim being led toward a forested area by one of the accused, followed by gunshots. He later executed a supplemental affidavit, prompted by recurring dreams, wherein he implicated appellant Dela Cruz, claiming he saw him carrying a wooden paddle and joining the others in the forest where the killing occurred.
The defense presented an alibi, with appellant claiming he was at a different location attending a wake during the time of the incident. The Regional Trial Court convicted appellant of murder qualified by treachery and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction. Appellant appealed to the Supreme Court, arguing the trial court erred in giving credence to Anthony’s inconsistent testimony and in finding conspiracy and treachery.

ISSUE

The core issue is whether the prosecution proved appellant’s guilt for the crime of murder beyond reasonable doubt, particularly regarding the existence of conspiracy and the qualifying circumstance of treachery.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court held that the alleged inconsistencies in Anthony Villacorta’s testimonies were minor and did not pertain to the core fact of appellant’s participation in the killing. The initial omission of appellant’s name was sufficiently explained by the witness’s fear and young age, and the supplemental affidavit merely provided greater detail without contradicting his essential narrative. The Court found his testimony credible, straightforward, and consistent on material points.
Regarding conspiracy, the Court ruled it was sufficiently established by the collective actions of appellant and his co-accused before, during, and after the crime. Their concerted movement toward the isolated forested area, their shared intent evidenced by earlier threats overheard by Zenaida Soriano, and their coordinated attack on the victim demonstrated a community of criminal purpose. Treachery was correctly appreciated because the attack was sudden, from behind, and employed in an isolated location, ensuring the victim, who was intoxicated and unable to defend himself, had no opportunity for resistance. The Court modified the damages awarded, increasing civil indemnity and moral damages to PhP 75,000 each and exemplary damages to PhP 30,000, in line with prevailing jurisprudence.