G.R. No. L-32865. May 18, 1984. THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO BENARABA, CESAR BENARABA, and VIRGILIO BENARABA, accused-appellants.
FACTS

This is an automatic review of a conviction for multiple murder. The case stemmed from a dispute over a debt and land sale agreement between Marcialito de Leon and spouses Fidel Benaraba. After the estafa case filed by the Benarabas was dismissed, Antonio Benaraba threatened Marcialito. On April 6, 1968, while Marcialito and his wife were away, their four young children were left at home. Prosecution witness Aniceto Canazares saw appellants Antonio, Cesar, and Virgilio Benaraba walking in a crouched position toward the de Leon house. Another witness, Cesar Magsino, later heard children crying in agony from the house and saw the three Benaraba brothers inside. The Benarabas left around 7:00 PM. The house was later discovered on fire, and the charred bodies of the four children were found inside.
The appeals of Antonio and Cesar Benaraba were dismissed by the Supreme Court due to their deaths pending review. Thus, the review proceeded only for Virgilio Benaraba. The defense presented alibi, claiming Virgilio was at a neighbor’s house during the incident.

ISSUE

Whether the guilt of appellant Virgilio Benaraba for the crime of multiple murder has been proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed Virgilio Benaraba’s conviction, modifying the penalty. The Court found the prosecution evidence, consisting of credible eyewitness testimony and circumstantial evidence, sufficient to establish guilt beyond reasonable doubt. Witnesses positively identified Virgilio and his brothers at the scene immediately before and during the crime. The medical findings confirmed the children died from severe burns and traumatic injuries. The Court rejected the defense of alibi, as it was not physically impossible for Virgilio to have been at the crime scene, which was only about 400 meters away, and the testimony was uncorroborated. The established motive—the Benarabas’ anger from the dismissed estafa case and their subsequent threat—further supported the finding of guilt. The collective failure of the Benaraba family to attend the victims’ funeral was also noted as indicative of a guilty conscience. For lack of the necessary votes for the death penalty, the Court modified the sentence, imposing four penalties of reclusion perpetua for the four murders and ordering indemnity to the heirs.