GR 189326; (November, 2010) (Digest)
G.R. No. 189326; November 24, 2010
PEOPLE OF THE PHILIPPINES, Appellee, vs. FRANCISCO RELOS, SR., Appellant.
FACTS
Appellant Francisco Relos, Sr., along with several relatives, was charged with Murder for the killing of his cousin, Ramon Relos, Sr., on December 26, 2005. The prosecution alleged that the group, armed with knives, bolos, and a hand grenade, conspired to attack, stab, and hack the victim, resulting in his death. The incident began when the victim and his son, Ramon, Jr., were walking along a highway. Appellant was leaning on his fence, while his brother Oliver and son Francisco, Jr. were nearby. Oliver approached the victim, greeted him, and drew a knife. Appellant then approached from behind and hacked the victim on the shoulder, followed by Francisco, Jr. hacking the other shoulder. Oliver proceeded to stab the victim multiple times. The victim’s son was chased away by other accused. The attack culminated in Oliver decapitating the victim and displaying the head.
The Regional Trial Court found appellant, Oliver, and Francisco, Jr. guilty of Murder, sentencing appellant and Oliver to reclusion perpetua. The Court of Appeals affirmed the conviction, upholding the findings of conspiracy and the qualifying circumstance of treachery. Appellant elevated the case to the Supreme Court.
ISSUE
Whether the Supreme Court should affirm appellant’s conviction for Murder, particularly regarding the existence of conspiracy and the qualifying circumstance of treachery.
RULING
The Supreme Court denied the appeal and affirmed the conviction with modification to the awarded damages. The Court upheld the factual findings of the lower courts, emphasizing that the trial court’s assessment of witness credibility is accorded great respect and finding no reason to deviate from it. The testimonies of eyewitnesses, particularly the victim’s son Ramon, Jr., were found credible and consistent with the physical evidence.
On the legal aspects, the Court affirmed the presence of conspiracy. Appellant’s act of suddenly hacking the victim from behind, synchronized with the initial greeting and attack by Oliver, demonstrated a unity of purpose and a concerted design to kill. Conspiracy was evident from the coordinated and successive actions of the assailants. Furthermore, the Court affirmed the qualifying circumstance of treachery. The attack was swift and unexpected, executed in a manner that deprived the unarmed victim of any opportunity to defend himself or retaliate. The victim was distracted by Oliver’s greeting and was immediately assaulted by appellant from behind, with attacks following in rapid succession. This method of attack was deliberately adopted to ensure the execution without risk to the assailants. The Court modified the damages, increasing civil indemnity to ₱75,000, moral damages to ₱75,000, and exemplary damages to ₱30,000, while maintaining an award of ₱25,000 as temperate damages.