G.R. No. 90627 November 29, 1991
People of the Philippines vs. Ramon Lao y Ricardo, et al.

FACTS

The seven accused-appellants were inmates of Cell No. 3 at the Lucena City Jail. On the evening of May 21, 1986, a drinking spree was underway within the cell. The victim, fellow inmate Norberto Reynoso, was singing. The session turned violent when appellant Ramon Lao gave a signal, prompting appellant Roberto Divino and others to assault Reynoso. They boxed and kicked him. A prison guard responded to shouts for help but, after a warning, left the scene. The appellants then barricaded the cell door. Lao ordered, “Patayin na si Reynoso.” The group collectively attacked Reynoso with a piece of wood and a makeshift knife, inflicting multiple fatal injuries. Police eventually subdued the inmates by cutting the bars and using tear gas. A post-mortem examination confirmed the severe injuries caused.
At trial, only Divino admitted participation. The other appellants denied involvement, claiming they were asleep, were pacifiers, or were framed by other inmates who testified for the prosecution. The trial court found all seven guilty of murder qualified by treachery and abuse of superior strength, sentencing each to reclusion perpetua and ordering indemnity. They appealed, challenging the credibility of the prosecution witnesses.

ISSUE

Whether the trial court erred in convicting all seven appellants of murder based on the evidence presented.

RULING

The Supreme Court affirmed the convictions. The appeal raised purely factual issues concerning witness credibility. The Court upheld the trial court’s factual findings, emphasizing the rule that the trial judge’s assessment of witness demeanor and credibility is entitled to the highest respect. The trial court correctly rejected the appellants’ denials and alibis as unworthy of belief compared to the positive, consistent, and credible testimonies of eyewitnesses who were their cellmates. The Court found conspiracy was sufficiently established by their coordinated actions: Lao gave the signal to attack, the group collectively assaulted the victim, barricaded the door to prevent intervention, and obeyed Lao’s order to kill. In conspiracy, the act of one is the act of all, making each liable for the murder regardless of who inflicted the fatal blow. The qualifying circumstance of treachery was present due to the sudden and unexpected attack that ensured the victim’s defenselessness. The Court noted that abuse of superior strength was absorbed by treachery. While quasi-recidivism was present, it did not alter the penalty as reclusion perpetua was already the maximum imposable under the 1987 Constitution . The Court increased the civil indemnity to P50,000 and referred the jail’s administrative lapses to the Secretary of Justice.