G.R. No. 192251 ; February 16, 2011
People of the Philippines, Plaintiff-Appellee, vs. Barangay Captain Tony Tomas, Sr., Benedicto Doctor, and Nestor Gatchalian, Accused-Appellants.

FACTS

On July 19, 2006, around 10:00 PM in Barangay Baybayaos, Mayantoc, Tarlac, Estrella Doctor Casco was walking home with her mother Damiana and caretakers Liezl Toledo and Angelita Duque after a medical check-up. Accused-appellants Tony Tomas, Sr. (Estrella’s cousin and former property administrator), Benedicto Doctor (Estrella’s cousin), and Nestor Gatchalian (farm helper of Tomas, Sr.) suddenly emerged from the roadside. Without a word, Tomas, Sr. drew a gun and shot Estrella twice from about 1.5 meters away. When she fell, he fired three more shots at her prone body. Gatchalian positioned himself in a blocking stance on the road, while Doctor pointed a gun at Damiana and Angelita, ordering them to lie face down. The scene was illuminated by a lamppost, enabling Liezl and Angelita to recognize the assailants. Estrella was declared dead on arrival at the hospital, with autopsy findings of four gunshot wounds, including one that perforated her heart. The prosecution witnesses cited possible motives, including Tomas, Sr.’s removal as administrator of Estrella’s properties and his loss in several cases against her family. The accused denied involvement, each claiming to have been asleep at home during the incident. They were arrested the next day and tested negative for gunpowder burns.

ISSUE

Whether the Court of Appeals correctly affirmed the Regional Trial Court’s decision finding accused-appellants Tony Tomas, Sr., Benedicto Doctor, and Nestor Gatchalian guilty beyond reasonable doubt of the crime of Murder.

RULING

The Supreme Court DENIED the appeal and AFFIRMED WITH MODIFICATION the Decision of the Court of Appeals. The accused-appellants were found guilty beyond reasonable doubt of Murder qualified by treachery.
The Court upheld the credibility of the prosecution eyewitnesses, Liezl Toledo and Angelita Duque. Their positive identification of the accused-appellants was deemed credible and reliable, as the crime scene was well-lit by a lamppost, allowing for clear recognition. Their testimonies were consistent and detailed on material points. The defense of alibi was rejected as it could not prevail over the positive identification by credible witnesses. The Court found that the accused-appellants acted in conspiracy, as their coordinated actions—Tomas, Sr. as the shooter, Gatchalian as a blocker, and Doctor as a lookout/threat to the companions—demonstrated a unity of purpose to kill Estrella.
The qualifying circumstance of treachery was present because the attack was sudden and unexpected, giving the unarmed victim no opportunity to defend herself or escape. Evident premeditation was not proven. The negative paraffin test results did not exculpate Tomas, Sr., as such tests are not conclusive.
The penalty of reclusion perpetua was affirmed. The awards for damages were modified: Civil indemnity was increased to PhP 75,000; moral damages to PhP 75,000; and exemplary damages to PhP 30,000. Actual damages were reduced to PhP 285,416.33, supported by receipts. The award for loss of earning capacity in the amount of USD 368,000 was affirmed. All monetary awards shall earn legal interest at 6% per annum from the finality of the judgment until fully paid.