GR 30924; (September, 1978) (Digest)
G.R. No. L-30924 September 30, 1978
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARNULFO BANGSAL, alias Arnul, and SATURNINO DE LOS REYES, alias Catot, accused. SATURNINO DE LOS REYES, accused-appellant.
FACTS
On March 3, 1969, in Binmaley, Pangasinan, Rizalino Victorino was fatally stabbed. Prosecution eyewitness Adelina Zarate testified that from her window, she saw accused Arnulfo Bangsal and Saturnino de los Reyes simultaneously attacking the victim. Bangsal, armed with a kitchen knife, was positioned at Rizalino’s back, while De los Reyes, armed with a small bolo, was partly in front. The victim was in a kneeling position with hands raised, pleading for them to stop. Adelina fainted after seeing blood. The victim’s brother, Eugenio Victoria, arrived and heard Rizalino’s dying declaration, identifying his assailants as “Annul” and “Catot,” the nicknames of Bangsal and De los Reyes. The autopsy revealed eleven wounds, including a fatal stab to the heart. Bangsal later surrendered with the murder weapon.
De los Reyes denied involvement, claiming he arrived after the killing and tried to stop Bangsal. He suggested Adelina testified falsely due to a prior petty dispute. His testimony, however, contradicted his earlier sworn statement to the police. The trial court convicted both of murder. Bangsal withdrew his appeal, leaving De los Reyes to contest his conviction.
ISSUE
The core issue is whether the guilt of appellant Saturnino de los Reyes for the crime of murder was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The legal logic rests on the credibility and corroboration of prosecution evidence. The eyewitness account of Adelina Zarate, given in a clear and consistent manner, was found credible by the trial court and upheld on appeal. Her testimony was substantially corroborated by the victim’s ante-mortem declaration to his brother, which directly identified both assailants. The physical evidence—multiple stab wounds inflicted from both the back and front of the victim—logically indicated the concerted action of two assailants using different weapons, consistent with the prosecution’s narrative.
The Court found that the manner of attack demonstrated a community of design between Bangsal and De los Reyes. By positioning themselves on opposite sides and attacking simultaneously while the victim was kneeling and defenseless, they employed abuse of superior strength to ensure the killing. This circumstance qualified the homicide to murder. The Court clarified that while the trial court appreciated treachery, the proper qualifying circumstance was abuse of superior strength, which under the facts absorbed treachery. The appellant’s denial and implausible alibi could not overcome the positive identification and corroborated evidence establishing his guilt beyond a moral certainty. The penalty of reclusion perpetua was thus affirmed.