People v. Tejero
REITERATIONFacts
The Antecedents: The accused-appellants Efren Tejero, Lucio Porton, Cesar Tejero, and Arnel Tejero were charged with murder for the killing of Alfredo Balase on June 18, 1995, at around 1:00 A.M. inside the auditorium of Barangay San Pedro, Municipality of Biri, Northern Samar. The Information alleged that the accused, armed with a bladed weapon and a stick, conspired to kill Alfredo Balase through treachery and evident premeditation, inflicting multiple stab wounds that caused his death. Procedural History: The Regional Trial Court of Catarman, Northern Samar, Branch 20, found all four accused guilty of murder and sentenced them to reclusion perpetua, with joint and several indemnity to the heirs of the victim. The accused appealed the decision. The Petition: The accused-appellants contended that the trial court erred in convicting them based on conspiracy, in not giving credence to Efren Tejero's claim of self-defense, in not acquitting the other appellants due to reasonable doubt, and in holding that treachery attended the commission of the crime.
Issue(s)
Whether the trial court correctly held all appellants equally liable for the death of the victim on the basis of conspiracy. Whether treachery was sufficiently proven to sustain the appellants' conviction for murder. Whether Efren Tejero acted in self-defense. Whether the defenses of alibi and denial interposed by Cesar Tejero and Lucio Porton were valid.
Ruling
The appeal is denied. The decision of the Regional Trial Court convicting Efren Tejero, Cesar Tejero, and Lucio Porton of murder and sentencing them to reclusion perpetua, with civil indemnity and costs, is affirmed. The conviction of Arnel Tejero, who escaped from jail, is deemed final and executory.
Ratio Decidendi
On the issue of conspiracy: The Court affirmed the trial court's finding of conspiracy, stating that it exists when two or more persons agree to commit a felony and decide to commit it. Conspiracy need not be proven by direct evidence; it is sufficient that the accused acted in concert with a common design and purpose. The evidence showed that the appellants acted in unison: Efren Tejero initiated the attack, while Cesar Tejero and Lucio Porton immobilized the victim, and Arnel Tejero delivered the fatal blows, with Efren acting as a lookout. Their familial relationship and presence at the scene further supported the conspiracy. As conspirators, they are liable as co-principals, the act of one being the act of all. On the issue of treachery: The Court found that treachery attended the commission of the crime. Treachery is characterized by a sudden and unexpected attack without provocation, depriving the victim of any chance to defend himself. Efren Tejero's act of approaching Alfredo while the latter was resting and then suddenly stabbing him, without Alfredo having any inkling of the impending attack, constituted treachery. The fact that Alfredo was facing Efren at the moment of the attack did not negate treachery, as the attack was still sudden and unexpected, giving Alfredo no opportunity to prepare for his defense. The success or failure of the initial thrusts was also deemed insignificant in establishing treachery. On the issue of self-defense: The Court rejected Efren Tejero's claim of self-defense. For self-defense to prosper, there must be unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. Efren admitted that after Alfredo stumbled and dropped his bolo, he picked it up and stabbed Alfredo multiple times. The Court ruled that the unlawful aggression had ceased once Efren gained possession of the weapon, negating the element of self-defense. Furthermore, the number of stab wounds inflicted indicated an intent to kill, not merely to defend. On the issue of alibi and denial: The defenses of alibi and denial by Cesar Tejero and Lucio Porton were found unmeritorious. Their houses were located a mere 20 and 50 meters, respectively, from the locus criminis, making their physical presence at the scene possible. These defenses cannot prevail over the positive testimonies of prosecution witnesses who positively identified them as participants in the crime. Minor discrepancies in the testimonies of prosecution witnesses do not detract from the core fact of their presence and participation.
Main Doctrine
Conspiracy is sufficiently established by the concerted action of the accused, acting in unison with the same purpose and common design, even without direct evidence of a prior agreement. The presence of treachery is determined by the manner of the attack, which deprives the victim of an opportunity to defend himself, regardless of whether the attack was frontal or successful.