People v. Solares
REITERATIONFacts
The Antecedents: Armando Solares, along with four other individuals (Rodolfo Solates, Enrico de los Santos, Roberto de los Santos, and Olly Fernandez), was charged with Murder for the killing of Baltazar Mercado. The information alleged that the accused conspired, mutually helped one another, with deliberate intent to kill, treachery, and evident premeditation, they attacked and stabbed Baltazar Mercado with an adobe stone, causing his death. Procedural History: Only Armando Solares was arraigned as the other accused remained at large. The prosecution presented eyewitness Estrella Cunanan, who testified that she saw the victim being held by the accused Armando Solares and Junior Solares while Enrico de los Santos repeatedly stabbed the victim. Roberto de los Santos shouted encouragement, and Olly Fernandez hit the victim on the head with an adobe stone, causing him to fall. The victim was pronounced dead on arrival at the hospital. The medico-legal examiner testified that the cause of death was cardio-respiratory arrest due to shock and hemorrhage from multiple stab wounds. The trial court found the appellant guilty beyond reasonable doubt of Murder, sentencing him to reclusion perpetua and ordering him to indemnify the heirs of the deceased. The Petition: The accused-appellant appealed the decision, assigning as errors the trial court's giving credence to the lone eyewitness and its appreciation of the qualifying circumstances of conspiracy and treachery.
Issue(s)
Whether the trial court gravely erred in giving much credence to the version of the lone eyewitness. Whether the trial court gravely erred in appreciating the qualifying circumstances of conspiracy and treachery in convicting the accused-appellant of murder.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding the accused-appellant guilty beyond reasonable doubt of Murder. The penalty of reclusion perpetua was upheld, along with the civil indemnity and reimbursement of expenses.
Ratio Decidendi
On the credibility of the lone eyewitness: The Court reiterated that a trial court's factual conclusions carry great weight due to its opportunity to observe the demeanor of witnesses. It is of no moment that the prosecution presented a lone eyewitness; if her uncorroborated testimony is credible and positive, it is sufficient for conviction. The trial court found the eyewitness's testimony logical, straightforward, and probable, and her credibility was not shaken on cross-examination. The delay in her testimony was satisfactorily explained by the appellant's apprehension date and the fact that co-accused were still at large. On conspiracy and treachery: The presence of conspiracy was clearly established as the assailants were animated by a common purpose to inflict harm on the victim. In conspiracy, the act of one is the act of all, rendering the specific act of stabbing by one individual inconsequential to the liability of the conspirators. Regarding treachery, the Court found that the victim was completely helpless, with both his hands held by the attackers, and facing five assailants. This situation clearly indicates that the assailants adopted means and methods to insure the commission of the offense without risk to themselves, and the victim was unprepared and unarmed, thus satisfying the elements of treachery. The defense of alibi and the alleged friendship between the appellant and the victim could not prevail over the straightforward narration of the eyewitness.
Main Doctrine
In conspiracy, the act of one is the act of all. Treachery is present when the victim is held and unable to defend himself, even if the attack is frontal. The credibility of a lone eyewitness, if found to be credible and positive, is sufficient for conviction.