People v. Asoy
REITERATIONFacts
The Antecedents: On February 24, 1989, in Purok Malakas, Lagao, General Santos City, the victim, Jaime Sunga, was accosted by Eduardo Asoy, Leopoldo Asoy, Maurino Obidos, and Miguel Pajuta, who were armed with knives. The victim was stabbed by the assailants, resulting in his death. Hermelino Perez, an eyewitness and uncle of the victim, testified that he saw Eduardo Asoy stab the victim in front. He also intervened by striking Maurino Obidos with a bamboo pole, causing him to fall and flee, along with his companions. Procedural History: The Regional Trial Court of General Santos City found Eduardo Asoy guilty of murder and sentenced him to reclusion perpetua, with damages. The other three accused remained at large. Eduardo Asoy appealed his conviction. The Petition: The accused-appellant contended that the prosecution failed to prove his guilt beyond reasonable doubt, arguing that the eyewitness did not clearly see the stabbing and that only Maurino Obidos stabbed the victim. He also argued that even if he were a co-conspirator, he should only be liable for homicide as the aggravating circumstances of treachery and nighttime were disregarded.
Issue(s)
Whether the guilt of the accused-appellant for murder was proven beyond reasonable doubt. Whether the aggravating circumstance of abuse of superior strength was properly considered, and the effect of conspiracy. Whether the accused-appellant should be held liable for murder or homicide, and the applicable penalty.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding the accused-appellant Eduardo Asoy guilty of murder and sentencing him to reclusion perpetua. The death indemnity was increased to P50,000.00. The conviction was based on the eyewitness testimony and the presence of the qualifying circumstance of abuse of superior strength.
Ratio Decidendi
On whether the guilt of the accused-appellant for murder was proven beyond reasonable doubt: The Court held that the testimony of the lone eyewitness, Hermelino Perez, was positive and credible. Perez clearly identified Eduardo Asoy as one of those who stabbed the victim, Jaime Sunga, stating that Asoy was in front of the victim when he stabbed him. The Court reiterated the principle that the testimony of a single witness is sufficient for conviction if found to be credible and that witnesses are weighed, not numbered. The trial court's assessment of the witness's credibility was given great respect and was not disturbed as no plain oversight of facts of weight and influence was found. Furthermore, the accused-appellant's flight after the incident, hiding and traveling to distant cities, was considered evidence of guilt, as it indicated a guilty conscience. The Court found no error in the trial court's conviction of the appellant for murder. On whether the aggravating circumstance of abuse of superior strength was properly considered, and the effect of conspiracy: The trial court disregarded treachery as an aggravating circumstance. However, the Court found that the qualifying circumstance of abuse of superior strength was present. The victim was unarmed and defenseless, while the four accused were armed with bladed weapons and collectively overwhelmed him. This collective strength used to overpower a comparatively defenseless victim constitutes abuse of superior strength, which is a qualifying circumstance for murder. The Court found that conspiracy was clearly manifest through the concerted action of the accused in surrounding and stabbing the victim, demonstrating a unity of purpose and design. On whether the accused-appellant should be held liable for murder or homicide, and the applicable penalty: The Court affirmed the conviction for murder. The qualifying circumstance of abuse of superior strength was established. This qualifying circumstance, as provided under Article 248 of the Revised Penal Code, elevates the crime from homicide to murder. The penalty for murder, in the absence of other modifying circumstances and with the presence of a qualifying circumstance, is reclusion perpetua in its medium period.
Main Doctrine
The presence of abuse of superior strength as a qualifying circumstance is sufficient to classify the crime as murder, even if treachery is not proven. Flight is indicative of guilt. The testimony of a single credible witness is sufficient for conviction.