G.R. No. 224289 . August 14, 2019.
THE PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. DANG ANGELES Y GUARIN, ACCUSED-APPELLANT.

FACTS

Accused-appellant Dang Angeles, along with three others at large, was charged with Murder for the death of Abelardo Evangelista and two counts of Frustrated Murder against Eric and Mark Ryan Evangelista. The incident occurred on April 27, 2010, in Binmaley, Pangasinan. The prosecution evidence established that the Evangelista brothers were at a family celebration when they were attacked by the group. Appellant initially stabbed another brother, Elmer. When Abelardo rushed to help, he was stabbed by multiple assailants, including appellant who used an icepick. Eric and Mark Ryan were also stabbed during the melee. Abelardo died, while Eric and Mark Ryan survived after medical treatment.
The defense presented a different version, claiming appellant was merely a bystander who was himself assaulted by the Evangelistas after attempting to pacify a commotion. The Regional Trial Court convicted appellant of Murder and two counts of Frustrated Murder, finding conspiracy and the qualifying circumstance of treachery. The Court of Appeals affirmed the conviction but modified the penalties. Appellant appealed to the Supreme Court.

ISSUE

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

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court found the testimonies of the prosecution witnesses, Eric and Mark Ryan Evangelista, to be credible, consistent, and positive in identifying appellant as a direct participant in the attacks. Their narration that the assault was sudden and unexpected, leaving the victims no opportunity to defend themselves, validly established the qualifying circumstance of treachery for Murder. For the Frustrated Murder charges, the prosecution proved that the acts of execution, performed with intent to kill, would have resulted in death were it not for timely medical intervention.
The defense of denial and frame-up was rejected for being inherently weak and unsupported by clear and convincing evidence. The claim of self-defense was likewise unavailing as appellant failed to prove unlawful aggression on the part of the victims. The Court upheld the finding of conspiracy, as appellant’s concerted actions with his co-accused in simultaneously attacking the victims demonstrated a community of criminal purpose. The penalties and awards of damages were affirmed with modification, imposing interest on all monetary awards at the legal rate of six percent per annum from the finality of judgment until full payment.