G.R. No. L-21325 October 29, 1971
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PABLEO DRAMAYO, PATERNO ECUBIN, PRIOLO BILLONA, FRANCISCO BILLONA, MODESTO RONQUILLA, CRESCENCIO SAVANDAL and SEVERO SAVANDAL, defendants; PABLEO DRAMAYO and PATERNO ECUBIN, defendants-appellants.

FACTS

On January 9, 1964, appellants Pableo Dramayo and Paterno Ecubin, along with the deceased Estelito Nogaliza, visited the chief of police of Sapao, Surigao del Norte, regarding a prior robbery at Nogaliza’s house. They were treated as suspects. Later that evening, Dramayo convened a group, including the other named accused, for a drinking session where he proposed killing Nogaliza to prevent him from testifying in the robbery case. A plan was hatched for Dramayo and Ecubin to ambush Nogaliza upon his return. When Nogaliza was sighted, Ecubin struck him on the head with a piece of wood, and Dramayo repeatedly stabbed the prostrate victim with a bolo. Dramayo then warned the others to remain silent. The next morning, Dramayo informed the victim’s widow of the body. The police chief, noticing blood stains on Dramayo’s trousers, received an implausible explanation about a skin ailment.
The trial court convicted Dramayo and Ecubin of murder, sentencing them to reclusion perpetua. Two co-accused were utilized as state witnesses, and three others were acquitted due to insufficient evidence of their direct participation in the killing, the court finding serious doubt as to their guilt based on their testimonies and the prosecution’s failure to refute their alibis. The appellants interposed alibis, which the trial court found unpersuasive.

ISSUE

Whether the conviction of the two appellants must be overturned because the information alleged conspiracy among seven defendants, but only they were convicted, thereby creating a reasonable doubt as to their guilt.

RULING

The Supreme Court affirmed the conviction. The appeal, based on the novel theory that the acquittal of some alleged conspirators negates the guilt of those convicted, is without merit. The Court meticulously reviewed the evidence and found it sufficient to establish the appellants’ guilt beyond reasonable doubt. The lower court correctly assessed the evidence, finding the testimonies of the state witnesses credible and the appellants’ alibis weak. The legal principle is clear: an information charging several persons with conspiracy does not require the conviction of all to sustain the conviction of some. The guilt of each accused must be determined individually based on the evidence presented against them. The acquittal of the three co-accused was justified by the trial court’s finding of insufficient evidence linking them directly to the execution of the crime, a finding entitled to respect. This outcome does not cast doubt on the compelling evidence against Dramayo and Ecubin, which detailed their direct, concerted actions in ambushing and killing Nogaliza. The presumption of innocence was overcome by proof meeting the standard of moral certainty. The decision highlights that conspiracy, as a mode of committing a crime, does not demand identical proof or identical results for every person named; what is crucial is the quality of evidence proving the individual culpability of the accused.