GR 99258; (September, 1991) (Digest)
G.R. No. 99258 September 13, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FRANCISCO ARROYO and RITO MINA, accused-appellants.
FACTS
Accused-appellants Francisco Arroyo and Rito Mina were convicted of murder for the killing of Nonito Villarosa. The evidence established that after a dance party, the victim, appellants, and a companion, Giddy Diaz, were walking home. A heated argument ensued between Mina and Villarosa regarding a debt. Upon reaching Sitio Tumalonton, Diaz heard Villarosa shout that he had been stabbed by Mina. Diaz ran to assist but was pushed away by Arroyo. He then witnessed Arroyo stab the victim twice in the back while Mina held Villarosa’s arm. The body was later found concealed under burl palms. Arroyo surrendered to the police, turning over the knife used in the crime.
The trial court found both guilty, sentencing them to indeterminate penalties. On appeal, the Court of Appeals affirmed the conviction but modified the penalties, imposing reclusion perpetua on Mina. Consequently, the case was elevated to the Supreme Court for automatic review.
ISSUE
The core issue is whether the guilt of accused-appellants for the crime of murder was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the judgment of the Court of Appeals. The prosecution evidence, primarily the credible and consistent eyewitness account of Giddy Diaz, sufficiently established appellants’ guilt. Diaz positively identified both Arroyo and Mina as the perpetrators, detailing how Mina held the victim, enabling Arroyo to inflict the fatal stab wounds. This testimony was corroborated by the physical evidence and the post-mortem findings.
The Court rejected the defenses of alibi and denial proffered by the appellants. For alibi to prosper, it must be shown that the accused was at another place for such a period that it was physically impossible for them to be at the scene of the crime. Mina failed to meet this stringent requirement. Arroyo’s claim of self-defense was likewise untenable; his act of surrendering the weapon and the nature of the victim’s multiple wounds, including those inflicted from behind, were inconsistent with a spontaneous struggle and negated his narrative. The concerted actions of holding the victim and stabbing him from behind demonstrated treachery, qualifying the killing to murder. The penalties and increased indemnity awarded by the appellate court were upheld.