G.R. No. L-35578. February 23, 1989.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PEDRITO DETALLA, ROGELIO DETALLA and ISIDRO DETALLA, defendants, ROGELIO DETALLA and ISIDRO DETALLA, defendants-appellants.

FACTS

The brothers Pedrito, Rogelio, and Isidro Detalla were charged with Murder for the killing of Cesar de la Pena on September 1, 1971, in Ozamis City. The information alleged conspiracy, treachery, and the use of superior strength. Pedrito pleaded guilty, while Rogelio and Isidro pleaded not guilty. After trial, the court convicted all three and sentenced them to reclusion perpetua. Rogelio and Isidro appealed, contesting the denial of their motion for new trial based on recanting affidavits from prosecution witnesses and arguing that the killing was not murder but a result of Pedrito acting alone in self-defense against an ambush by the deceased.
The prosecution evidence, primarily from eyewitnesses Maximo and Virginia de la Pena (brother and sister of the victim), established that earlier animosity existed between Isidro and the victim. On the evening of the killing, Rogelio and the victim had a fistfight, which the victim won. Later, as the victim walked home, Isidro hurled a stone at him, causing him to fall. Pedrito and Rogelio then rushed in and hacked the victim to death with bolos. The defense presented a contrary version, claiming the victim ambushed Pedrito with a bolo, and Pedrito alone fought back in self-defense, accidentally killing the victim.

ISSUE

The core issue is whether the guilt of appellants Rogelio and Isidro Detalla for the crime of Murder was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction, finding the appellants’ guilt established beyond reasonable doubt. The Court rejected the defense of self-defense, noting it was unsubstantiated and illogical. The nature, number, and severity of the victim’s wounds—including amputated arms—were inconsistent with a sudden, accidental encounter and indicated a determined, concerted attack. The medical testimony that the wounds were likely inflicted by more than one similar bolo corroborated the prosecution’s theory of multiple assailants, negating the claim that Pedrito acted alone.
The Court also upheld the denial of the motion for new trial based on recanted affidavits. Recantations are notoriously unreliable and viewed with extreme caution, as they can easily be obtained through coercion or monetary consideration. The trial court correctly gave greater weight to the witnesses’ original testimonies given in open court, which were clear, consistent, and credible. The established facts demonstrated a conspiracy: Isidro initiated the attack by throwing the stone, and Pedrito and Rogelio executed the fatal hacking. The collective action of the three brothers, following a prior altercation, established the qualifying circumstance of treachery, as the attack was sudden and rendered the victim defenseless. The penalty of reclusion perpetua was thus proper, though the civil indemnity was increased to P30,000.00.