People v. Leneses
REITERATIONFacts
The Antecedents: Appellants Constantino Leneses alias "Alex Remonte" and Leon David alias "Junior", along with three others, were charged with the murder of Charlie Celadeña y Lim. The prosecution presented witnesses who testified that on August 24, 1967, the victim was stabbed by the accused. Go Hong testified seeing Edwin Vengco stab the victim while Leneses and others moved away, all armed. Rolando Quiane testified about an earlier incident between Celadeña and Vengco, and later heard a commotion and found Celadeña bleeding. Purita Delgado corroborated this, stating she saw Celadeña being held by two men, one identified as Leon David, while others stabbed him. Dr. Mariano de Lara's autopsy revealed eleven stab wounds, five of which were fatal. Procedural History: The lower court (Court of First Instance of Manila, Branch XX) found both appellants guilty of murder, sentencing them to reclusion perpetua, indemnification of P12,000.00, and costs. The Petition: Appellants Constantino Leneses and Leon David appealed their conviction.
Issue(s)
Whether the trial court erred in relying on the testimonies of prosecution witnesses Go Hong, Rolando Quiane, and Purita Delgado; and whether the evidence presented by the prosecution was sufficient to convict the appellants. Whether there was proof of conspiracy among the accused. Whether the crime committed was murder qualified by abuse of superior strength, evident premeditation, and treachery.
Ruling
The judgment of the lower court finding appellants Constantino Leneses and Leon David guilty of murder is AFFIRMED, with the modification that they shall pay, jointly and severally, the heirs of the deceased the sum of P30,000.00.
Ratio Decidendi
On the credibility of prosecution witnesses and sufficiency of evidence: The Court held that when there is no showing of improper motive on the part of witnesses, their clear and positive testimony is worthy of full faith and credit, even if they are neighbors or friends of the victim. Purita Delgado's testimony, corroborated by Go Hong, was deemed credible. The Court reiterated that the testimony of a single credible witness, if it satisfies the court beyond reasonable doubt, is sufficient for conviction. The defense of alibi, as presented by Constantino Leneses, is considered weak and easily concocted, and it dwindles in the face of positive identification. The positive identification of appellant Leneses as one of the perpetrators diminished the efficacy of his alibi. The Court found no inconsistencies or contradictions in the prosecution witnesses' testimonies. On the existence of conspiracy: The Court found the conspiracy among the appellants and their companions to be easily discernible from their conduct, both before and immediately after the commission of the crime. Their concerted actions in assaulting Charlie Celadeña clearly indicated an agreement to kill him. The Court cited the rule that conspiracy may be inferred if it is proven that two or more persons aimed by their acts towards the accomplishment of the same unlawful object, each doing a part so that their acts, although apparently independent, were in fact connected and cooperative, indicating a closeness of personal association and concurrence of sentiment. This was supported by the fact that Leon David left Manila for Cavite and hid himself until his arrest, which the Court considered highly indicative of guilt, and his explanation of fear of Edwin Vengco was not impressive. On the qualification of the crime: The Court agreed with the trial court that the crime committed was murder, qualified by abuse of superior strength. The prosecution's evidence regarding the commission of the crime and the manner of its perpetration, including the circumstance of abuse of superior strength, was not disputed. Appellant Leon David and his witness confirmed these facts. The Court noted that no generic aggravating circumstance, such as nighttime, evident premeditation, and treachery, was sufficiently proved by the prosecution. No mitigating circumstance was shown by the defense. Therefore, the medium of the penalty prescribed for murder, which is reclusion perpetua, was imposed.
Main Doctrine
The conspiracy among the appellants and their companions was discernible from their conduct, showing a concurrence of sentiment and cooperation towards the unlawful object of killing the victim. The positive identification of an appellant, coupled with the weakness of alibi, is sufficient for conviction. Abuse of superior strength was qualified the crime to murder.