People v. Maralit
REITERATIONFacts
The Antecedents: Lope Maralit and Romy Pasia were charged with the murder of Jaime Cordelin. Four individuals were initially charged, but two remained at large, one died in custody, and Pasia was acquitted by the lower court. Maralit and Pasia were employees of International Realty Corporation, with Maralit being the foreman and Pedro Pacheca (deceased) the overseer. The victim had a pending land dispute with the Corporation. The prosecution alleged that Maralit, Pasia, Pacheca, and Manang Mendoza fired shots at the victim and his two sons from an elevated position. The victim sustained multiple gunshot wounds, with most entering his back. The cause of death was hemorrhage due to multiple gunshot wounds. The motive stemmed from the land dispute, with prior threats and burning of the victim's huts by the accused and their companions. Procedural History: The Municipal Court of Carmona, Cavite, filed a criminal complaint. An Amended Information charged Maralit and Pasia with Murder. Upon arraignment, both pleaded not guilty. The trial court acquitted Pasia on grounds of reasonable doubt but convicted Maralit of Murder, qualified by treachery, sentencing him to reclusion perpetua and ordering him to indemnify the heirs. The defense of Maralit was denial and alibi, claiming they were at their place of work at the time of the incident, corroborated by the plantation manager and Maralit's sister-in-law. The Petition: Accused-appellant Maralit appealed, contending that the court erred in not finding that the conspiracy involved only the two gun wielders and that his presence at the scene was merely passive, warranting acquittal on reasonable doubt, as he did not carry a firearm.
Issue(s)
Whether conspiracy to commit murder was sufficiently established against accused-appellant Maralit. Whether accused-appellant Maralit's defense of alibi should prevail over the positive identification by prosecution witnesses. Whether the crime committed was Murder qualified by treachery. Whether the penalty imposed by the trial court should be modified in light of the 1987 Constitution.
Ruling
The Supreme Court affirmed the conviction of Lope Maralit for Murder but modified the penalty. The indeterminate sentence imposed was ten (10) years and one (1) day of prision mayor as minimum, to eighteen (18) years, eight (8) months and one (1) day of reclusion temporal as maximum.
Ratio Decidendi
On the issue of conspiracy: The Court held that conspiracy was sufficiently established against Maralit. The eyewitnesses positively declared that Maralit was in the company of the actual assailants, Pacheca and Mendoza, on the elevated area from where the shots were fired. His presence in a crouching position near the other assailants as shots were fired, coupled with prior antecedents like having threatened the victim and his closeness of personal association and concurrence of sentiment, evidenced knowledge of and intentional participation in the common criminal intent. The Court reiterated that conspiracy need not be proven by direct evidence but can be inferred from the collective acts of the accused, and the act of one conspirator is the act of all. The fact that Maralit did not carry a firearm did not negate his participation in the conspiracy, as he was lending at least moral aid. The Court cited People vs. Liza and People vs. Beltran in support of the principle that the act of one is the act of all. On the defense of alibi: The Court found Maralit's alibi unmeritorious. His claim of being at his place of work was contradicted by the positive identification made by credible prosecution witnesses who saw him at the crime scene. Furthermore, the distance between his alleged location and the crime scene was only about four kilometers, which was easily accessible by vehicles, making it not impossible for him to have been present at the commission of the crime. The Court emphasized that for alibi to be considered, it must be established that it was impossible for the accused to be at the scene of the crime at the same time, citing People vs. Manangan and People vs. Ornoza. On the qualification of treachery: The Court affirmed that the crime committed was Murder qualified by treachery (alevosia). The sudden and unexpected attack caught the victim unaware, and the four wounds with entrances on the back of the victim further bolstered the attendance of treachery. The assailants perched themselves on an elevated area, ensuring the victim was attacked without risk to them, as held in People vs. Abubakar Asil. The Court noted that the visibility was not impaired despite some small trees, as the police investigators confirmed the assailants could still be seen even in a crouching position. On the modification of penalty: The Court modified the penalty imposed by the trial court. While the trial court imposed reclusion perpetua, the 1987 Constitution abolished capital punishment. Therefore, the penalty for Murder is now reclusion temporal in its maximum period to reclusion perpetua. In the absence of modifying circumstances, the penalty is imposed in its medium period. For purposes of the Indeterminate Sentence Law, the Court determined the range of the penalty next lower to that prescribed by the Revised Penal Code.
Main Doctrine
Conspiracy to commit murder can be proven by circumstantial evidence, and the act of one conspirator is the act of all. Alibi cannot prevail over positive identification by credible witnesses, especially when the distance to the crime scene is not impossible to traverse.