People v. Hayahay
REITERATIONFacts
The Antecedents: Accused-appellants Antolin Hayahay, Orlando Licanda, Edito Comedia, Serapin Moreles, Zaldy Billentes, Miliano Olasiman, Dionisio Olasiman, and Antonio Olasiman were charged with and convicted of murder for the killing of Gorgonio Lapu-Lapu on November 2, 1990, in Barangay Sto. Niño, San Vicente, Palawan. The Information alleged that the accused, conspiring, confederating, and mutually helping one another, with evident premeditation and treachery, and by means of superior force, attacked, assaulted, stabbed, boxed, and hit the victim with a piece of wood and an iron bar, inflicting multiple incised and stab wounds that resulted in hemorrhagic shock and instantaneous death. Procedural History: The prosecution relied on the testimony of Ramil Lapu-Lapu, the victim's brother and sole eyewitness. Ramil testified that he saw all eight accused participate in the mauling and stabbing of Gorgonio. The autopsy report by Dr. Joselito Vicente confirmed eleven stab wounds, with four being fatal. The accused interposed the defenses of denial and alibi. The Regional Trial Court found all accused guilty beyond reasonable doubt of murder and sentenced each to reclusion perpetua, to indemnify the heirs of the victim, and to pay costs. The Petition: The accused-appellants appealed the RTC decision, arguing that the trial court erred in giving weight to the eyewitness testimony of Ramil Lapu-Lapu, in not acquitting them due to insufficient proof beyond reasonable doubt, and in finding conspiracy, treachery, and abuse of superior strength.
Issue(s)
Whether the trial court gravely erred in giving weight and credence to the testimony of the prosecution eyewitness. Whether the accused-appellants were proven guilty beyond reasonable doubt. Whether the trial court erred in finding that conspiracy existed and that the crime was committed with the attending qualifying circumstances of treachery and abuse of superior strength.
Ruling
The Supreme Court affirmed the decision of the trial court, finding all accused-appellants guilty beyond reasonable doubt of the crime of Murder. They were sentenced to reclusion perpetua and ordered to indemnify the heirs of the victim.
Ratio Decidendi
On the credibility of the eyewitness testimony: The Court found the inconsistencies alluded to by the appellants in Ramil Lapu-Lapu's testimony to be more apparent than real. Ramil provided a detailed "eyeball account" of the killing and the specific participation of each appellant from a distance of five meters, under the illumination of a full moon and kerosene lamps. The Court reiterated that the testimony of a single witness, if straightforward and categorical, is sufficient to convict, and credibility does not depend on numbers. The Court found no ill-motive on Ramil's part, noting that as the victim's brother, he would be interested in seeing the true assailants brought to justice. On the guilt of the accused beyond reasonable doubt: The Court found the alibis of the appellants to be weak and insufficient to exculpate them. Their alibis failed to demonstrate physical impossibility of their presence at the crime scene, and in some instances, were not corroborated by credible witnesses or evidence. For instance, appellant Hayahay's claim of being on the second floor was not corroborated by the neighbor whose house he claimed to be in. Appellant Miliano Olasiman's offer of compromise was considered an implied admission of guilt. The Court concluded that the prosecution successfully proved its case beyond reasonable doubt. On conspiracy and qualifying circumstances: The Court affirmed the trial court's finding of conspiracy, stating that it need not be shown by direct proof of agreement but can be inferred from the conduct of the malefactors before, during, and after the crime. The collective and individual acts of the appellants, including their approach to the victim, the use of weapons, and their simultaneous mauling and stabbing, demonstrated a common design to kill. The Court also upheld the appreciation of treachery and abuse of superior strength. The attack was sudden and unprovoked, giving the victim no chance to defend himself, and the use of multiple assailants armed with weapons against an unarmed victim clearly showed a notorious inequality of force, ensuring the execution of the crime without risk to the offenders.
Main Doctrine
The collective and individual acts of the accused before, during, and after the commission of the crime are sufficient to prove conspiracy. Once conspiracy is proven, the act of one is the act of all. The qualifying circumstances of treachery and abuse of superior strength were properly appreciated given the sudden, unprovoked attack on the unarmed victim by multiple assailants armed with weapons, demonstrating a notorious inequality of force.