G.R. No. L-44810 May 21, 1984
The People of the Philippines, plaintiff-appellee, vs. Armando Seda y Puros and Ricardo Austria y Caag, defendants-appellants.

FACTS

The case involves three consolidated criminal cases arising from an ambush on July 5, 1975. At around 1:00 AM, Station Commander Bienvenido Ariola was driving his two daughters, Edna and Elsa, home from a dance in Laurel, Batangas. Upon reaching Barrio Leviste, their jeep was fired upon. Bienvenido and Edna were killed instantly. The jeep crashed into a coconut tree, throwing Elsa to the ground, unharmed but dazed. She saw three armed men approach the vehicle. She positively identified two of them as appellants Armando Seda and Ricardo Austria. She heard Seda kick her father’s head and say “Ayos na” before they left. Elsa immediately reported the incident to her uncle, naming Seda and Austria as the assailants. Police investigation recovered fifteen empty shells at the scene. The appellants were apprehended later that same day.
At trial, both appellants pleaded not guilty and interposed the defense of alibi. The trial court convicted them of Murder with Direct Assault for the killing of Bienvenido Ariola, Murder for the killing of Edna Ariola, and Attempted Murder against Elsa Ariola. The crimes were qualified by treachery and evident premeditation, with nocturnity as an aggravating circumstance. They were each sentenced to reclusion perpetua for the two murder charges and a prison term for attempted murder, plus damages.

ISSUE

The core issue is whether the guilt of appellants Armando Seda and Ricardo Austria was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the convictions with modification on the indemnity. The Court upheld the trial court’s rejection of the appellants’ alibi in light of the positive and credible identification by eyewitness Elsa Ariola. The defense of alibi is inherently weak and cannot prevail over the positive testimony of a credible witness who had no motive to falsely testify. The Court found Elsa’s testimony candid and sincere, delivered without any ill motive against the appellants. Furthermore, the appellants themselves had motive against the deceased Chief of Police, as Seda was forced to resign from the police force by Ariola, and Austria was berated by him for drunkenness.
The Court also addressed the appellants’ argument regarding the fifteen empty shells suggesting only one firearm was used, which they claimed contradicted the testimony about three assailants. The Court ruled this does not negate conspiracy; it is possible only one fired, or that the others used different weapons, and the concerted actions established their common criminal design. The existence of conspiracy was manifest from their collective approach and actions after the shooting. The Court also clarified that the polygraph test mentioned was not a factor in determining guilt. The aggravating circumstances of nocturnity and superior strength were correctly considered absorbed in treachery. However, the Court modified the judgment by increasing the civil indemnity for the deaths to P30,000.00 each. The penalties imposed by the trial court were affirmed as being in accordance with law and the evidence.