GR 196735; (May, 2014) (Digest)
G.R. No. 196735, May 5, 2014
People of the Philippines v. Danilo Feliciano, Jr., Julius Victor Medalla, Christopher Soliva, Warren L. Zingapan, and Robert Michael Beltran Alvir
FACTS
On December 8, 1994, around 12:30-1:00 PM, seven members of the Sigma Rho fraternity were eating lunch at the Beach House Canteen near the Main Library of the University of the Philippines, Diliman. They were suddenly attacked by several masked men armed with baseball bats and lead pipes. The attack resulted in injuries to several Sigma Rho members and the death of Dennis Venturina. Separate Informations for murder (for Venturina’s death) and attempted/frustrated murder (for the injuries to other victims) were filed against multiple members of the Scintilla Juris fraternity. The prosecution witnesses, who were the victims, identified the accused-appellants during the attack: Leandro Lachica identified Robert Michael Beltran Alvir (after his mask fell off), Warren Zingapan, and Julius Victor Medalla; Mervin Natalicio identified Warren Zingapan and Christopher Soliva; Cesar Mangrobang, Jr. identified Danilo Feliciano, Jr. (beating Venturina with a lead pipe) and Raymund Narag; Cristobal Gaston, Jr. and Amel Fortes also identified Danilo Feliciano, Jr., Warren Zingapan, and George Morano at the scene. Venturina died on December 10, 1994, from traumatic head injuries. The accused raised defenses of alibi and denial, claiming they were elsewhere during the incident.
ISSUE
Whether the accused-appellants are guilty beyond reasonable doubt of the crime of Murder for the death of Dennis Venturina.
RULING
The Supreme Court affirmed the conviction of the accused-appellants for Murder. The Court found the testimonies of the prosecution witnesses credible, consistent, and positive in identifying the appellants as perpetrators. The witnesses knew the appellants from the university setting, and their identifications were made under circumstances ensuring reliability (e.g., masks falling off, appellants not wearing masks). The defenses of alibi and denial cannot prevail over positive identification. The killing was qualified by treachery because the attack was sudden and unexpected, giving the victims no opportunity to defend themselves. The Court modified the damages awarded, increasing civil indemnity, moral damages, and exemplary damages to Php75,000 each, and awarding temperate damages of Php25,000. The Court emphasized the need to end impunity for fraternity violence.