G.R. No. L-64164 June 22, 1984
People of the Philippines, plaintiff-appellee, vs. Alejandro Banayo, defendant-appellant.

FACTS

The appellant, Alejandro Banayo, was convicted of Murder by the Regional Trial Court of Lucena City for the killing of Armando Abel. The information alleged that on September 13, 1980, in Dolores, Quezon, Banayo, conspiring with Donato Alvero and Rosendo “Chito” Villanueva, attacked and stabbed Abel with treachery. Only Banayo was arrested and tried. Prosecution witnesses Romualdo Cabrera and Alfredo Esguerra testified that after an initial stone-throwing altercation, the victim, Armando Abel, arrived at the scene. They categorically stated that while Banayo and Alvero held Abel’s hands, Villanueva stabbed him from behind. The barangay captain later found the victim, who subsequently died from multiple fatal wounds.
The defense interposed alibi, claiming Banayo had left the scene because his mother was ill and was not present during the stabbing. The trial court’s decision, while notably brief and lacking in citation, convicted Banayo of Murder qualified by treachery and sentenced him to “life imprisonment.” On appeal, Banayo challenged the credibility of prosecution witnesses and the findings of conspiracy and treachery.

ISSUE

The primary issue is whether the prosecution evidence sufficiently proves the appellant’s guilt for the crime of Murder, particularly the existence of conspiracy and the qualifying circumstance of treachery.

RULING

The Supreme Court affirmed the conviction but modified the penalty and indemnity. The Court found the testimonies of prosecution witnesses credible and consistent, establishing that Banayo and Alvero held the victim, enabling Villanueva to stab him from behind. This coordinated action proved conspiracy, as it demonstrated a unity of purpose and design among the assailants, which can be inferred from their concerted acts without need for proof of a prior agreement.
The killing was properly qualified as Murder by treachery. The means of execution—holding the victim’s hands to immobilize him while he was stabbed from behind—directly insured the commission of the offense without risk to the assailants from any defense or retaliation by the victim. This method was deliberately adopted. The Court corrected the penalty imposed by the trial court, stating that the proper term is reclusion perpetua, not “life imprisonment,” due to the distinct legal accessories attached to specific penalties. The indemnity was increased to Thirty Thousand Pesos. The judgment was modified accordingly.