G.R. Nos. 78359-60 November 23, 1988
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DESIDERIO ALIOCOD y GARAN and FLAVIANO DAIRO y GALINATO, defendants-appellants.

FACTS

In the early morning of December 26, 1983, appellants Desiderio Aliocod (the barangay captain and CHDF team leader), Flaviano Dairo, and Pio Aliocod, armed with firearms and hunting knives, went to the house of Jose Galope and his son Edgardo in Bukidnon. The trio fetched the victims and brought them to a nearby hill, where they were encircled by about fifty armed men. After the victims failed to return, their family and neighbors searched and found their headless bodies on the hill with multiple stab wounds. Chief Sanitary Inspector Ernesto Abejuela confirmed the victims died from sharp-bladed instruments and decapitation.
Subsequently, Desiderio confessed to Elias Aquilam during a drinking session that they killed two alleged NPA members, decapitated them with rattan instruments, and even ate their ears. Desiderio later tried, but failed, to get barrio inhabitants to sign a document attesting the victims were NPA. While in detention, Desiderio also confessed to police officers, leading them to where the victims’ heads were buried. The skulls were exhumed and identified by a family member. Two separate murder informations were filed against the appellants.

ISSUE

Whether the guilt of appellants Desiderio Aliocod and Flaviano Dairo for the crime of murder was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the trial court’s decision finding the appellants guilty of murder. The Court upheld the positive identification by prosecution witness Gerardo Quinlog, who clearly saw the appellants fetch the victims from a distance of twenty meters without obstruction, finding no reason to disturb the trial court’s assessment of witness credibility. The appellants’ defenses were unavailing. The claim that they were armed only with firearms was negated by Desiderio’s own admission that members of his group carried hunting knives, which could have inflicted the stab wounds. The argument that the fifty other armed men should be prosecuted was rejected, as Desiderio, being the leader, bore responsibility for the acts of his group.
The Court ruled that motive was not essential since the appellants were positively identified. Nevertheless, a motive was established through Desiderio’s statements that the victims were alleged NPA members. While there was no eyewitness to the actual killing, the circumstantial evidence—comprising the abduction, the discovery of the bodies with corresponding wounds, the confessions to multiple parties, the recovery of the skulls, and the failed attempt to justify the killings—formed an unbroken chain leading to the reasonable and conclusive guilt of the appellants for murder. The penalty of reclusion perpetua and the awarded damages were sustained.