G.R. Nos. L-45407-08 September 28, 1984
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EMILIO URBISTONDO and RAYMUNDO (MUNDO) URBISTONDO, defendants-appellants.

FACTS

On the evening of January 30, 1971, in Amaya, Tanza, Cavite, an altercation occurred between Emilio Urbistondo and Augusto Perea. Emilio was angered upon seeing Augusto conversing with Mary, Emilio’s sister-in-law, as he disapproved of Augusto’s courtship. After an exchange of words and a brief scuffle that was pacified by bystanders, the parties separated. Emilio later returned with his brothers, Antonio and Raymundo. When Augusto and his father, Venancio Perea, arrived at the scene, the Urbistondo brothers suddenly attacked. Emilio stabbed Augusto, Raymundo struck him with an ice pick, and Antonio hacked him with a bladed instrument. After Augusto fell mortally wounded, the trio then assaulted Venancio, inflicting serious injuries. Augusto died shortly after arriving at the hospital.
Appellants raised separate defenses. Emilio claimed self-defense, alleging he was attacked by a masked intruder whom he later realized was Augusto, and that he also stabbed Venancio when the latter hit him with a bottle. Raymundo denied participation, asserting he was at home when Emilio arrived to recount the incident, prompting him to flee. The trial court convicted both of murder for Augusto’s death and frustrated murder for the attack on Venancio, imposing the death penalty for murder.

ISSUE

The core issue is whether the trial court correctly convicted the appellants of murder and frustrated murder, rejecting their defenses of self-defense and alibi, and finding conspiracy.

RULING

The Supreme Court affirmed the convictions but modified the penalty. The Court upheld the trial court’s factual findings and rejection of the appellants’ defenses. For self-defense, the burden of proof rests on the accused, who must rely on the strength of his own evidence, not the weakness of the prosecution’s case. Emilio’s claim was unconvincing; his immediate flight and prolonged evasion of arrest were conduct inconsistent with a person acting in legitimate self-defense. Raymundo’s alibi was worthless against the positive identification by eyewitnesses Caridad Batayola and Venancio Perea, and his own flight bolstered the inference of guilt.
The legal logic for finding conspiracy was based on the appellants’ collective and simultaneous actions. Their coordinated armed attack—Emilio with a knife, Raymundo with an ice pick, and Antonio with a bladed weapon—demonstrated unity of purpose and design to assault the victims. This concerted effort established conspiracy, making each co-conspirator equally liable for the acts of the others. The attack was sudden and unexpected, rendering the victims unable to defend themselves, which properly qualified the killing as murder through treachery. The Court modified the penalty for murder to reclusion perpetua due to the lack of necessary votes for the death penalty and increased the civil indemnity.