GR 228886; (August, 2018) (Digest)
G.R. No. 228886 , August 8, 2018
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. CHARLIE FLORES, DANIEL FLORES and SAMMY FLORES, Accused-Appellants
FACTS
On December 25, 2002, Larry Parcon and Eduardo Mabini were on a motorcycle that ran out of fuel in front of a videoke bar in Real, Quezon. Larry entered the bar while Eduardo went to buy fuel. Hearing a commotion, Eduardo entered and saw Larry pacifying accused-appellants Sammy and Daniel, who were fighting. Suddenly, Rodel Torestre (at large) stabbed Larry. When Eduardo shouted, Sammy and Daniel turned on him and punched him. Eduardo fell down the stairs. He then saw Sammy and Daniel, armed with knives, alternately stabbing Larry while accused-appellant Charlie Flores held Larry by the armpits. Another co-accused, Gary Badeviso (at large), stabbed Larry in the head. Larry suffered five fatal stab wounds and was pronounced dead on arrival. The accused-appellants raised the defense of denial and alibi, claiming they were elsewhere during the incident, which was corroborated by their respective witnesses.
ISSUE
The core issue is whether the prosecution proved the guilt of accused-appellants Charlie, Daniel, and Sammy Flores for the crime of Murder beyond reasonable doubt, particularly concerning their positive identification and the qualifying circumstance of abuse of superior strength.
RULING
The Supreme Court affirmed the conviction for Murder but modified the damages. The Court upheld the positive identification of the accused-appellants by the lone eyewitness, Eduardo Mabini. His testimony was found credible, consistent, and given without ill motive. The Court ruled that his proximity to the event—being just an arm’s length away—and the sufficient illumination inside the bar allowed for a clear view, making his identification reliable. The defenses of denial and alibi cannot prevail over this positive identification, especially as the accused failed to prove it was physically impossible for them to be at the crime scene.
On the qualifying circumstance, the Court affirmed the presence of abuse of superior strength. The attack was collectively carried out by multiple armed assailants against an unarmed victim who was also restrained (held by Charlie Flores). This situation clearly shows the assailants took advantage of their combined strength to ensure the victim could not defend himself, qualifying the killing as Murder under Article 248 of the Revised Penal Code. The Court modified the awarded damages, increasing civil indemnity, moral damages, and exemplary damages to ₱100,000.00 each, and awarding temperate damages of ₱50,000.00, all with 6% interest per annum from finality until full payment.