G.R. No. 247824 . February 23, 2022.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ORLANDO PADILLA AND DANILO PADILLA, ACCUSED-APPELLANTS.

FACTS

An Information dated June 18, 2010, charged Orlando Padilla and Danilo Padilla with Murder for the killing of Rhandy Padin on March 29, 2010, in Naguilian, La Union, with abuse of superior strength. The prosecution’s eyewitness, tricycle driver Antonio Villanueva, testified that he drove the Padilla brothers and later Rhandy. During the trip, a fight ensued inside the tricycle. Upon stopping, the brothers pulled Rhandy out. Danilo boxed Rhandy while Orlando choked him. Danilo retrieved a knife from the tricycle and, while Orlando restrained Rhandy by choking him and twisting his arm, stabbed Rhandy. When Rhandy gained possession of the knife, Orlando stepped on his hand, retrieved it, and gave it back to Danilo. After the knife bent, Danilo used a big stone to hit Rhandy’s head. With Rhandy motionless, the brothers, with Antonio’s help, threw him into a ravine. Danilo then dropped a bigger stone and the knife into the ravine. The medico-legal report stated the cause of death was blunt traumatic head injury, with injuries consistent with being hit by a stone and stabbed. The defense presented a different version. Danilo claimed it was Antonio who stabbed Rhandy after a quarrel over drinks and that he and Orlando were forced to help dispose of the body. Orlando denied participation, claiming he ran away upon hearing Antonio’s intent to kill. The Regional Trial Court found both accused guilty of Murder qualified by abuse of superior strength and attended by conspiracy, sentencing them to reclusion perpetua without eligibility for parole and ordering them to pay damages. The Court of Appeals affirmed the RTC decision.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellants Orlando Padilla and Danilo Padilla for the crime of Murder.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court found the testimony of eyewitness Antonio Villanueva credible, consistent, and corroborated by physical evidence. His detailed account of how both accused-appellants conspired to attack, restrain, stab, and bludgeon the victim established their guilt beyond reasonable doubt. The qualifying circumstance of abuse of superior strength was properly appreciated as the accused-appellants, acting in concert, employed force obviously disproportionate to the means of defense available to the unarmed victim. Conspiracy was duly proven through their coordinated actions indicating a common purpose to kill. The defenses of denial and alibi cannot prevail over positive identification. The penalty of reclusion perpetua without eligibility for parole was correctly imposed pursuant to prevailing jurisprudence. The awarded damages were modified in accordance with recent guidelines: civil indemnity, moral damages, and exemplary damages were increased to PHP 75,000.00 each, and temperate damages of PHP 50,000.00 were awarded. All monetary awards shall earn legal interest at 6% per annum from the finality of judgment until full payment.