G.R. Nos. 71875-76, January 25, 1988
People of the Philippines vs. Domingo Lopez y Cabais and Roberto Ansale y Tambuli

FACTS

On the evening of January 31, 1982, a group including Jaime Gloria and Jaime Cano left the Encounter Disco in Quezon City. Outside the establishment, appellants Domingo Lopez and Roberto Ansale suddenly attacked. Ansale first struck Cano on the neck with a balisong. As Cano and others fled, the appellants turned on Jaime Gloria, who was nearby, and took turns stabbing him multiple times. Gloria died from his wounds that same night. Cano survived after receiving medical treatment. Prosecution witnesses, including victim Jaime Cano, eyewitness Alex Pilapil (a parking boy at the disco), and companions Federico Malinao and Basilisa Polinar, positively identified Lopez and Ansale as the assailants. Their written statements were given to police soon after the incident.
The appellants denied involvement, presenting an alibi. Lopez, who worked at a nearby parking area, claimed he knew of no incident that evening. Ansale, corroborated by his wife and a beer house manager, asserted he did not report for work that night and was merely taken from his home by police. The trial court found these defenses unworthy of credence, characterizing the defense witnesses as evasive and not truthful, especially given the proximity of Lopez’s workplace to the crime scene.

ISSUE

The core issues were whether the appellants were correctly identified as the perpetrators, whether conspiracy and treachery were established, and the proper penalties to be imposed following the 1987 Constitution ’s abolition of the death penalty.

RULING

The Supreme Court affirmed the convictions but modified the penalties. The positive identification by multiple prosecution witnesses, given under clear circumstances, prevailed over the weak general denial and alibi of the appellants. The sudden and unexpected nature of the attack, which left the victims no opportunity to defend themselves, validly qualified the crimes to Murder and Frustrated Murder through treachery. Conspiracy was evident from their concerted actions in jointly assaulting the victims. The Court agreed with the defense that an extrajudicial confession from Ansale was inadmissible due to constitutional violations but ruled that the other evidence was more than sufficient to establish guilt beyond reasonable doubt.
Regarding penalties, the Court applied the constitutional prohibition on the death penalty. For Murder, the penalty was reduced to reclusion temporal maximum to reclusion perpetua. With no modifying circumstances, the indeterminate sentence imposed was ten years and one day of prision mayor as minimum to eighteen years, eight months and one day of reclusion temporal as maximum. Civil indemnity was increased to P30,000.00. For Frustrated Murder, the indeterminate penalty was set at four years, two months and one day of prision correccional as minimum to twelve years and one day of reclusion temporal as maximum. The awards for actual and moral damages were affirmed.