G.R. No. L-34089 August 1, 1978
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GAUDENCIO CANDADO y SARTE, REYNALDO SADIE y MALANA, and MANUEL MAGLALANG y MALDA, defendants-appellants.

FACTS

The accused-appellants, Gaudencio Candado, Reynaldo Sadie, and Manuel Maglalang, were convicted of Murder and sentenced to death by the Circuit Criminal Court of Pasig. The prosecution established that on September 1, 1970, the victim, Mario San Juan, was walking with two companions, Alberto Fernandez and Manuel Tawatao, in Pasay City. They encountered a group, including the three appellants, who were drinking. Apprehensive, they attempted to leave, but the appellants, armed with bolos, suddenly attacked San Juan. Fernandez witnessed Candado, Sadie, and Maglalang holding bolos and hacking the victim. San Juan sustained thirty wounds—eighteen stab wounds and twelve hacking wounds—as per the NBI medico-legal report, indicating at least two assailants using different bladed instruments. The victim died from hemorrhage. The defense consisted of alibis, which the trial court rejected.

ISSUE

The core issue for automatic review is whether the trial court correctly convicted the appellants of Murder, qualified by treachery, and properly imposed the death penalty.

RULING

The Supreme Court affirmed the conviction for Murder but modified the penalty to reclusion perpetua. The Court upheld the finding of treachery (alevosia). The attack was sudden and unexpected, launched from behind without any provocation, depriving the unarmed victim of any chance to defend himself. This manner of execution directly and specially ensured the accomplishment of the crime without risk to the assailants. The positive identification by eyewitness Alberto Fernandez, who had no motive to falsely testify, prevailed over the weak alibis of the appellants, which were not physically impossible. The Court also found conspiracy, as the appellants acted in concert with a common purpose to kill, evident from their simultaneous armed attack. However, the Court corrected the penalty. The trial court improperly appreciated the generic aggravating circumstance of “aid of armed men.” This circumstance does not apply when all participants, like the appellants here, acted under the same criminal design. With treachery as the sole qualifying circumstance and no other modifying circumstances present, the prescribed penalty for Murder under Article 248 of the Revised Penal Code is reclusion temporal in its maximum period to death. Applying the Indeterminate Sentence Law rules, the penalty should be imposed in its medium period, which is reclusion perpetua. Thus, the death sentences were reduced accordingly.