People v. Candado
REITERATIONFacts
The Antecedents: On September 1, 1970, Mario San Juan was hacked and stabbed to death. The Amended Information charged Gaudencio Candado y Sarte, Reynaldo Sadie y Malana, and Manuel Maglalang y Maida with Murder, alleging conspiracy, treachery, aforethought, and evident premeditation. Procedural History: The Circuit Criminal Court of Pasig, Rizal, convicted the accused as charged, sentencing each to death, indemnification, moral damages, exemplary damages, and costs. The Petition: The case was brought before the Supreme Court for automatic review.
Issue(s)
Whether the guilt of the accused was proven beyond reasonable doubt. Whether conspiracy was sufficiently established. Whether treachery was present. Whether the defense of alibi was credible.
Ruling
The Supreme Court affirmed the judgment of the lower court, with the modification that the penalty imposed on the appellants be reclusion perpetua instead of death.
Ratio Decidendi
On the guilt of the accused and the credibility of Alberto Fernandez: The Court found that the positive identification of the accused by Alberto Fernandez, an eyewitness, was sufficient to sustain a conviction. Fernandez's testimony was deemed more credible than the denials and alibis of the accused. The Court reiterated that alibi is a weak defense and must be proven by clear and satisfactory evidence, demonstrating the physical impossibility of the accused being at the scene of the crime. The Court also noted that the trial court, having had direct contact with the witnesses, was in a better position to assess their credibility. On the establishment of conspiracy: The Court found that conspiracy was sufficiently established by circumstantial evidence. The Solicitor General cited several circumstances, including the accused spotting the deceased's group, the simultaneous utterance of "ayun," the hacking of the deceased while his back was turned, the chase and swarming of the victim, and the numerous wounds inflicted, all indicating that the appellants acted in concert and pursued the same objective. The Court emphasized that conspiracy need not be proven by direct evidence and can be inferred from the attendant circumstances and the unity of purpose and execution. On the presence of treachery: The Court found that treachery attended the commission of the crime. The attack was deliberate, sudden, and unexpected, without giving the victim an opportunity to defend himself. The deceased was hacked and stabbed while running away and was surrounded by the appellants, who inflicted wounds upon him by turns. This manner of attack, rendering the victim unable to defend himself, constitutes treachery, which qualifies the killing as murder. On the credibility of the defense of alibi: The Court rejected the alibi of the accused. It found that the factors of distance, time, and means of travel did not preclude the possibility of the accused being at the scene of the crime. The alibis of Candado and Sadie were not sufficiently established, and Maglalang's alibi in Pampanga was also deemed not to preclude his presence in Pasay City. The Court further noted that corroborative witnesses for the defense had a clear interest in the fate of the accused, being friends and relatives, and that their testimonies were contradicted by positive eyewitness accounts.
Main Doctrine
The positive identification of the accused by an eyewitness, even if uncorroborated by other witnesses, is sufficient for conviction if the eyewitness is credible. Alibi, being a weak defense, must be proven by clear and satisfactory evidence and must show that it was physically impossible for the accused to be at the scene of the crime. Conspiracy can be proven by circumstantial evidence, and the act of one conspirator is the act of all.