GR 222655; (December, 2020) (Digest)
G.R. No. 222655 , December 09, 2020
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. EDJEN CAMARINO, ET AL., ACCUSED-APPELLANTS.
FACTS
The prosecution’s evidence established that on August 13, 2006, in Sitio Sanggaya, Talakag, Bukidnon, the victim Romeo Lajero was shot to death. Prosecution witness Eugenio Cahilog testified that at around 5:00 a.m., he heard successive gunshots and saw about 17 armed persons, whom he positively identified as his neighbors and relatives—including all eight accused-appellants—firing indiscriminately toward the store where the victim was. After the assailants left, Eugenio found Romeo’s bullet-riddled body. The victim’s wife, Lucia, corroborated hearing the gunshots and later discovering her husband’s body.
The accused-appellants interposed the defenses of denial and alibi. They collectively claimed they were elsewhere during the incident, such as in different towns or cities, and argued it was physically impossible for them to be at the crime scene. They further alleged that the principal witness, Eugenio, was biased and had motive to falsely implicate them due to their previous testimonies against him in a separate case.
ISSUE
Whether the accused-appellants are guilty beyond reasonable doubt of the crime of Murder.
RULING
Yes, the Supreme Court affirmed the conviction for Murder. The Court upheld the credibility of prosecution witness Eugenio Cahilog, whose positive identification of the appellants as perpetrators was clear, consistent, and credible. Being a relative and neighbor, he had a clear view and familiarity with them, and no ill motive for his testimony was proven. His account was corroborated by circumstantial evidence. The defenses of denial and alibi were correctly rejected as weak and inherently unreliable, especially when weighed against positive identification. The appellants failed to prove it was physically impossible for them to be at the crime scene, as the alleged distances were not convincingly established.
The Court affirmed the presence of conspiracy, deduced from the appellants’ collective and concerted actions in armed assembly and simultaneous firing, indicating a common purpose to kill. The qualifying circumstances of treachery and abuse of superior strength were properly appreciated. The attack was sudden and unexpected, depriving the unarmed victim of any chance to defend himself, and the appellants employed overwhelming force through their number and firearms. The penalty of reclusion perpetua was affirmed. The awards of damages were modified in line with prevailing jurisprudence, granting civil indemnity, moral and exemplary damages, and temperate damages, with accrued interest. The case against Sabelo Samontao was dismissed due to his supervening death.