GR 72742; (February, 1990) (Digest)
G.R. No. 72742 February 12, 1990
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TEOFILO OBANDO, DOMINADOR OBANDO, RECTO CABANBAN, FRANCISCO CABANBAN and VICTOR CABANBAN, accused-appellants.
FACTS
The accused-appellants were convicted of Murder for the killing of Oscar Magarro. The prosecution, through the testimonies of the victim’s wife and son, established that on November 18, 1983, the victim’s family was ambushed while riding a tricycle. Cipriano and Dominador Obando initially stopped the vehicle, after which Gregorio Vicente fired at Magarro. A gunfight ensued, during which Vicente was shot. When Magarro’s gun jammed, he was overpowered. The accused-appellants, along with others still at large, then dragged Magarro to a nearby house where they collectively assaulted him with various weapons, including guns, a knife, stones, a dustpan, a shovel, an iron harrow, and a piece of wood, leading to his death.
The defense presented alibis and a different narrative, claiming the incident was merely a gunfight between Magarro and Gregorio Vicente. Each accused denied participation, asserting they were elsewhere or hiding during the event. They argued the prosecution witnesses were biased and their testimonies inconsistent. The trial court rejected these defenses, finding the prosecution’s evidence credible and establishing conspiracy among the accused.
ISSUE
Whether the trial court erred in convicting the accused-appellants of Murder based on the evidence presented.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, emphasizing its superior position to observe demeanor. The detailed and consistent testimonies of the eyewitnesses, despite minor inconsistencies, were found credible and sufficient to establish the accused-appellants’ guilt beyond reasonable doubt. The Court ruled that conspiracy was clearly proven by the accused-appellants’ collective and simultaneous actions in ambushing and ganging up on the victim with a common purpose to kill. Under the doctrine of conspiracy, the act of one is the act of all, making each participant equally liable as a principal for the crime of Murder, regardless of who inflicted the fatal blow. The spontaneous and coordinated attack, motivated by pre-existing ill will, demonstrated their unity of criminal design. The penalty of Reclusion Perpetua was affirmed, with the civil indemnity modified to Thirty Thousand Pesos.