G.R. No. L-74953. June 30, 1987.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO LEGASPI and OSCAR LEGASPI, accused-appellants.

FACTS

The case stemmed from a stabbing incident at a barangay plaza in Miaga, Uson, Masbate, in the early morning of September 16, 1983, during a dance and canvassing event. The victim, Fausto Apalla, Jr., sustained multiple stab wounds from a machete and died nine days later. The prosecution’s case, primarily through the eyewitness account of 13-year-old Fernando Sanchez, alleged that accused-appellants Antonio Legaspi and Oscar Legaspi, without provocation, approached and attacked Apalla. Antonio first stabbed him in the chest and stomach, after which Oscar stabbed him on the wrist and hand. They then chased the victim, with Antonio inflicting a final wound on his buttock. The defense presented a different version. Antonio admitted the killing but claimed self-defense, asserting that Apalla had first pulled out a machete. Oscar interposed alibi, claiming he was asleep inside a nearby chapel during the incident, a claim corroborated by a teacher who testified she saw him there after the commotion.

ISSUE

The core issues were: (1) the credibility of the prosecution’s eyewitness and the validity of the appellants’ defenses, and (2) the proper classification and penalty for the crime committed.

RULING

The Supreme Court affirmed the trial court’s judgment of conviction for Murder. The Court found the testimony of prosecution witness Fernando Sanchez credible and sufficient to establish guilt beyond reasonable doubt. The plaza was well-lit, Sanchez was proximate to the event, and his relationship to the victim (as a nephew) did not automatically discredit his testimony. The Court rejected Antonio Legaspi’s claim of self-defense. The nature, number, and location of the wounds inflicted—and the fact that two assailants simultaneously attacked an unarmed victim—belied any lawful aggression on the victim’s part and instead demonstrated a determined effort to kill. The crime was properly qualified by treachery, as the attack was sudden and rendered the victim unable to defend himself. Oscar Legaspi’s defense of alibi was deemed weak and could not prevail over Sanchez’s positive identification, especially given the chapel’s proximity to the crime scene. The trial court correctly credited Antonio with the mitigating circumstance of voluntary surrender, resulting in a lower penalty for him (reclusion temporal) compared to Oscar (reclusion perpetua). The plea for incomplete self-defense was unavailing as the appellants were the clear aggressors. The awarded damages were sustained.