G.R. No. 74060 September 15, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CRESTITO HERMOSA and TITO HERMOSA, defendants-appellants.

FACTS

In the early morning of April 20, 1984, during a ritual session in the yard of Isabelo Hermosa in Barangay Aguada, Cataingan, Masbate, the victim Remegio Villanueva arrived. Suddenly, accused Tito Hermosa embraced Villanueva from behind, placing his arms around the victim’s neck and forcing him to lean backward. While Villanueva was thus restrained, his co-accused Crestito Hermosa rushed forward and stabbed Villanueva in the abdomen with a double-bladed knife, causing his instantaneous death. The two accused then fled together with the weapon. The incident was witnessed by Isabelo Hermosa and the ritual leader, Pacencio Enor, who both reported the matter to authorities. An autopsy confirmed a fatal stab wound.
The accused were charged with murder. At trial, the prosecution presented the eyewitness accounts of Isabelo Hermosa and Pacencio Enor, who consistently described the sudden and coordinated attack. In their defense, Crestito Hermosa claimed self-defense, alleging that the victim had attacked him first with a knife, leading to a struggle. Tito Hermosa interposed alibi, testifying that he was at home attending to his wife who was giving birth at the time of the incident.

ISSUE

Whether the guilt of accused-appellants Crestito Hermosa and Tito Hermosa for the crime of murder was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The trial court correctly gave full credence to the positive, clear, and corroborative testimonies of the two prosecution eyewitnesses, who had no ill motive to testify falsely. The minor variance between a witness’s account of a single stabbing and the autopsy report noting two wounds was deemed inconsequential, as it pertained to a detail secondary to the established fact of the fatal attack.
The defenses raised were correctly rejected. Tito Hermosa’s alibi was inherently weak, being corroborated only by his wife—an interested party—and failing to demonstrate the physical impossibility of his presence at the crime scene, which was within the same barangay. Crestito Hermosa’s claim of self-defense was unsubstantiated and flimsy, lacking any corroboration and being inconsistent with the evidence of a sudden, unprovoked assault. The manner of the attack—where Tito restrained the victim, enabling Crestito to stab him without risk—constituted treachery, qualifying the killing as murder. The concerted actions of the two accused clearly implied conspiracy. Thus, the judgment of the Regional Trial Court convicting them of murder and sentencing them to reclusion perpetua was affirmed.