G.R. No. L-67966 September 28, 1984
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARIO NAVOA, RAFAEL NAVOA, RICARDO SITCHON, MACARIO SAGUINZA, JOHN DOE and PETER DOE, defendants-appellants.

FACTS

This is a Motion for Reconsideration of the Court’s Decision dated July 31, 1984, which affirmed the conviction of appellants Mario Navoa, Rafael Navoa, and Ricardo Sitchon for the murder of Tomas Izon and sentenced them to reclusion perpetua. The appellants assigned two errors. First, they contended that the finding of guilt was not supported by the evidence. Second, they asserted that the death of appellant Mario Navoa on June 14, 1984, which was manifested before the Intermediate Appellate Court on June 20, 1984, was not properly considered in the Supreme Court’s Decision.
The prosecution’s case relied heavily on the testimony of co-accused Macario Saguinza, who turned state witness, and witness Baltazar de la Rosa. The appellants argued that Saguinza’s testimony was unreliable and that inconsistencies in de la Rosa’s testimony weakened the prosecution’s case. Regarding Mario Navoa’s death, counsel manifested it to the Appellate Court, unaware that the case had already been certified to the Supreme Court, which subsequently rendered its Decision without knowledge of his demise.

ISSUE

The core issues are: (1) whether the evidence sufficiently supports the conviction for murder, and (2) what the legal effects are of an appellant’s death pending appeal.

RULING

The Court denied the Motion for Reconsideration on the merits but modified the judgment concerning the deceased appellant. On the first issue, the Court held the conviction was firmly supported by evidence. The Intermediate Appellate Court’s assessment of witness credibility, particularly its finding that minor inconsistencies in de la Rosa’s testimony strengthened his credibility, was affirmed. Crucially, the testimony of Saguinza, which remained unrebutted, was deemed sufficient to establish conspiracy, treachery, evident premeditation, and motive for the crime, thereby sustaining the conviction.
On the second issue, the Court ruled that the death of appellant Mario Navoa during the pendency of the appeal extinguished his criminal liability. However, his civil liability arising from the crime survived. The Court modified its prior Decision, setting aside the criminal conviction as against Mario Navoa but maintaining that his estate, jointly and severally with the surviving appellants Rafael Navoa and Ricardo Sitchon, is liable to indemnify the heirs of the victim in the amount of P30,000.00. The judgment of conviction and sentence of reclusion perpetua against Rafael Navoa and Ricardo Sitchon was affirmed.