G.R. No. 247654. June 14, 2021.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. SADICK ROARING Y RECTIN, SADJADE ROARING Y RECTIN, BELTRAN RELLAMA Y RECTIN, AND BREXTON RELLAMA Y BORAGAY, ACCUSED, SADICK ROARING Y RECTIN AND BELTRAN RELLAMA Y RECTIN, ACCUSED-APPELLANTS.

FACTS

Accused-appellants Sadick Roaring and Beltran Rellama, along with two others who remained at-large, were charged with two counts of Murder for the deaths of Fabian Renigen Rectin III and Fabian Requejo Rectin, Jr., and one count of Frustrated Murder against Virginia Rectin. The incidents occurred on May 1, 2014. The prosecution evidence established that the four accused, all armed with bolos and with Sadick also carrying a firearm, arrived at the victims’ shanty. Sadick fired shots and threatened to kill the family. Fabian Jr. was struck with a mortar and then hacked by all assailants. After Fabian Jr. died, they collectively hacked Fabian III. Subsequently, Sadick hacked Virginia, and his companions joined in the assault. Virginia survived by escaping. Sadick raised self-defense, claiming Fabian Jr. shot him first with a “sumpak,” and a struggle ensued where Virginia accidentally hacked Fabian Jr. and was later wounded when Sadick reversed a bolo she tried to use on him. The Regional Trial Court found accused-appellants guilty of two counts of Murder and one count of Frustrated Murder, qualified by treachery and abuse of superior strength, and sentenced them accordingly. The Court of Appeals affirmed the conviction.

ISSUE

Whether the Court of Appeals correctly affirmed the conviction of accused-appellants Sadick Roaring and Beltran Rellama for two counts of Murder and one count of Frustrated Murder.

RULING

Yes, the Supreme Court affirmed the conviction with modifications to the awarded damages. The prosecution proved the guilt of accused-appellants beyond reasonable doubt. The testimonies of the prosecution witnesses were credible and consistent on material points. The qualifying circumstances of treachery and abuse of superior strength were properly appreciated as the attacks were sudden and executed by a group armed with bolos and a firearm against unarmed victims, ensuring no risk to the assailants. Accused-appellants’ defenses of self-defense and denial were rejected for being uncorroborated, self-serving, and unbelievable, and cannot prevail over the positive identification by the prosecution witnesses who had no ill motive. The penalties imposed by the lower courts were affirmed. The Supreme Court modified the damages in accordance with prevailing jurisprudence: for each Murder count, accused-appellants are ordered to pay jointly and severally the heirs of the victims P75,000.00 as civil indemnity, P75,000.00 as moral damages, P75,000.00 as exemplary damages, and P50,000.00 as temperate damages. For Frustrated Murder, they are ordered to pay Virginia Rectin P50,000.00 as civil indemnity, P50,000.00 as moral damages, P50,000.00 as exemplary damages, and P50,000.00 as temperate damages. All monetary awards shall earn interest at 6% per annum from finality of the decision until fully paid.