G.R. No. L-12406, June 30, 1961
The People of the Philippines, plaintiff-appellee, vs. Floro Tila-on, Beltran Agrava and Victor Dazo, defendants-appellants.

FACTS

The three accused, Floro Tila-on, Beltran Agrava, and Victor Dazo, were convicted of murder for the killing of Severo Agustin and sentenced to reclusion perpetua. Tila-on later withdrew his appeal. The prosecution evidence established that on June 18, 1955, the three appellants arrived at the store-residence of Severo Agustin. While Severo turned his back to get cigarettes, Floro Tila-on suddenly stabbed him in the back. Beltran Agrava then delivered a second bolo thrust, and as the wounded Severo reached for his own bolo, Victor Dazo inflicted the final stab. Severo managed to wound Dazo on the thigh before collapsing. Three eyewitnesses—the victim’s wife, daughter, and a customer—consistently testified to this sequence.
The prosecution’s theory on motive was rooted in a prior 1952 robbery committed by Tila-on and others against the Agustin family, which Severo had reported to authorities despite death threats. The defense presented a contradictory version, claiming Severo was the aggressor, attacking Dazo out of jealousy, and that Tila-on killed Severo only in self-defense and in defense of Dazo during the ensuing struggle.

ISSUE

The core issue is whether the guilt of appellants Beltran Agrava and Victor Dazo for the crime of murder was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court meticulously analyzed the evidence, finding the testimony of the prosecution witnesses to be substantially coherent and credible. In stark contrast, the defense account was riddled with irreconcilable inconsistencies and improbabilities. For instance, the defense witnesses gave conflicting accounts of what Severo said before the alleged attack, the position of Victor Dazo during the fight, and whether a subsequent challenge from Severo’s son occurred. A critical improbability noted was that if, as the defense claimed, there was a close struggle where Severo was the armed aggressor, it was unlikely that all fatal stab wounds would be located on the back of his body.
The Court concluded the defense theory was a fabrication, noting the lack of motive for the prosecution witnesses to falsely testify. The simultaneous arrival of the accused, their concerted actions in successively attacking the victim from behind, and their collective presence throughout the crime sufficiently established conspiracy, making each liable as a principal. The sudden attack on an unsuspecting victim who was stabbed from behind constituted treachery (alevosia), qualifying the killing as murder. With no mitigating or aggravating circumstances proven, the penalty of reclusion perpetua was correctly imposed. The trial court’s findings, being supported by credible evidence, were upheld.