G.R. No. 214450 . August 10, 2016.
People of the Philippines, Plaintiff-Appellee, vs. Manuel Prado y Marasigan, Accused-Appellant.

FACTS

Accused-appellant Manuel Prado y Marasigan, together with three other co-accused who remained at large, was charged with Murder for the killing of PO1 Weddy Arato and with Frustrated Murder for the wounding of PO1 Pelagio Saludes (later SPO1 Saludes). The charges stemmed from an incident on April 15, 1999, in Canlubang, Laguna, where a police team responding to an illegal gambling report was fired upon by four armed men. SPO1 Saludes positively identified appellant in open court as one of the assailants, who was armed with a short firearm. The prosecution presented SPO1 Saludes, the victim’s father Panfilo Arato (for stipulations on damages), and Dr. Roy Camarillo. The defense interposed denial and alibi, claiming mistaken identity and that appellant was in Leyte at the time of his arrest in 2008, supported only by the testimony of his sister without documentary proof. The Regional Trial Court found appellant guilty of Murder and Attempted Murder, imposing reclusion perpetua for Murder and an indeterminate prison term for Attempted Murder, plus damages. The Court of Appeals affirmed the conviction with modifications to the damages awarded.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction for Murder and Attempted Murder.

RULING

The Supreme Court affirmed the conviction with modifications to the penalties and damages. The Court found no error in the lower courts’ findings. The positive identification by eyewitness SPO1 Saludes, whose testimony was found credible and straightforward, prevailed over the appellant’s unsubstantiated defenses of denial and alibi. The prosecution established all elements of Murder, including the qualifying circumstance of treachery, as the attack was sudden and unexpected, depriving the victims of any chance to defend themselves. Conspiracy was evident from the common intent and concerted actions of the armed assailants. For Murder (Criminal Case No. 6898-99-C), the penalty of reclusion perpetua was affirmed. The damages were modified in accordance with prevailing jurisprudence: civil indemnity, moral damages, and exemplary damages were set at ₱75,000.00 each. For Attempted Murder (Criminal Case No. 6899-99-C), the indeterminate sentence was modified to range from two (2) years, four (4) months, and one (1) day of prision correccional as minimum, to eight (8) years and one (1) day of prision mayor as maximum. The damages were modified to ₱25,000.00 each for civil indemnity, moral damages, and exemplary damages, plus ₱50,000.00 as temperate damages. All damages awarded shall earn interest at 6% per annum from the finality of the judgment until fully paid.