G.R. No. L-62654-58 November 13, 1986
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAMON DAGANGON, ET AL., accused-appellants.

FACTS

In the early dawn of May 18, 1978, in Barrio Mapula, Davao City, Vicente Guillena, Sr. and his two sons, Jimmy and Vicente, Jr., were brutally killed. Following the slayings, the assailants kidnapped four members of the Guillena household—Benito Gallo, Alfonsa Guillena, and her two minor children—and detained them for ten days. Separate criminal informations for three counts of murder and two counts of kidnapping and serious illegal detention were filed. Only six of the nine accused—Ramon Dagangon, Ramon “Ata” Mampintuan, Vedasto Lagapa, Maria Lagapa, Onciang Lagapa, and Candida Madelo—were apprehended and stood trial. The prosecution’s case hinged on the testimonies of the kidnapping victims, Benito Gallo and Alfonsa Guillena, who positively identified the appellants as participants in the crimes.
The trial court convicted all accused-appellants. On appeal, they challenged the credibility of the prosecution witnesses, arguing that their testimonies were inconsistent and that the witnesses failed to disclose the crimes immediately after their release. The appellants also denied involvement, presenting alibis and claiming the witnesses had ulterior motives. They specifically contended that the witnesses could not have seen the alleged “payoff” of money to the killers in the kitchen due to the house’s layout and the discreet nature such an act would entail.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellants beyond reasonable doubt for the crimes of murder and kidnapping with serious illegal detention.

RULING

The Supreme Court affirmed the convictions, with modification to the indemnity. The Court found the testimonies of Benito Gallo and Alfonsa Guillena credible and sufficient to establish guilt. The witnesses provided detailed and consistent accounts of the appellants’ participation, from the planning stages to the execution of the crimes and the subsequent kidnapping. The Court dismissed the claim that the witnesses could not have seen the kitchen payoff, noting the typical small, open layout of a provincial house without partitions, which made observation possible despite the accused’s attempt at privacy.
The Court ruled that conspiracy was clearly established by the evidence. The acts of Vedasto Lagapa in providing money and a rifle, Ramon Dagangon in supplying ammunition, and the collective presence and actions of the appellants demonstrated a united purpose to commit the crimes. Once conspiracy is proven, the act of one is the act of all. The appellants’ defenses of denial and alibi were deemed weak, self-serving, and could not prevail over the positive identification by credible eyewitnesses. The Court found no improper motive for the witnesses to falsely accuse the appellants, and their delayed reporting was reasonably explained by fear. The decision was affirmed with the modification of increasing the civil indemnity for each death to Thirty Thousand Pesos (P30,000.00).