G.R. No. 75295 March 17, 1993
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ESRAEL AMONDINA, AQUILLO CATAYTAY and ROMULO AMANTILLO, accused-appellants.

FACTS

The accused-appellants, Esrael Amondina, Aquillo Cataytay, and Romulo Amantillo, were convicted by the Regional Trial Court of Negros Oriental for the murder of Floro Gantalao and sentenced to reclusion perpetua. The killing occurred at twilight on February 23, 1983, in Poblacion, Mabinay, Negros Oriental. Prosecution witness Francisco Tangon testified that while pasturing his carabao, he saw the three accused sitting by the road. When Floro Gantalao arrived, they suddenly attacked him: Amondina hit him with a pestle on the left jaw, Cataytay hacked him with a long bolo on the head, and Amantillo struck him in the nape with a piece of wood as he lay helpless. The accused then fled. Tangon later reported the incident to the police, despite being warned by Amondina not to tell anyone. The victim’s wife, Manolita Gantalao, testified that she saw the three accused near the crime scene earlier that evening, and they appeared frightened and ran into the bushes. Police investigator Jomie Moreno recovered physical evidence: a blood-stained pestle from an uninhabited house, a blood-stained bolo and pants from Cataytay’s house, and a blood-stained machete from Amantillo’s house. The autopsy findings were consistent with the described attack. The defense of all three accused was denial and alibi, each claiming to have been at their respective homes at the time of the incident.

ISSUE

Whether the guilt of the accused-appellants for the crime of murder has been proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction but modified the civil indemnity. The Court found the prosecution’s evidence strong and credible. The positive identification by eyewitness Francisco Tangon, corroborated by the physical evidence recovered and the testimonies of the victim’s wife and the investigating officer, established the guilt of the accused beyond reasonable doubt. The alleged inconsistencies in the witnesses’ testimonies were not substantial enough to impair their veracity. The defense of alibi was weak and could not prevail over positive identification. The Court found that conspiracy existed among the three accused based on their concerted actions aimed at killing the victim. The killing was qualified by treachery due to the sudden and consecutive attacks that ensured the execution without risk to the assailants. However, the Court ruled that the circumstances of scoffing at the corpse and evident premeditation were not sufficiently proven. The penalty of reclusion perpetua was upheld. The civil indemnity was increased from P30,000.00 to P50,000.00, for which all accused-appellants are solidarily liable. The appeal was dismissed.