People v. Relos
REITERATIONFacts
The Antecedents: The accused, including appellant Francisco Relos, Sr., were charged with murder for the killing of Ramon Relos, Sr. The Information alleged that the accused, armed with knives, bolos, and a hand grenade, conspired to kill the victim with evident premeditation, treachery, and superior strength. On December 26, 2005, the victim and his son, Ramon, Jr., alighted from a jeepney. As the victim walked towards his brother's house, Oliver Relos greeted him and drew a knife. Appellant Francisco Relos, Sr. approached the victim from behind and hacked him with a bolo. Francisco, Jr. then hacked the victim's other shoulder, and Oliver stabbed him multiple times. Ramon, Jr. was chased by Francisco, Jr., Allan, and Larry when he tried to intervene. The victim fell, and Oliver allegedly decapitated him and threw the head on the road. Oliver also attempted to use a hand grenade against Gloria and Rogelio, Jr. Police arrived and arrested some of the accused. Procedural History: During arraignment, Oliver pleaded guilty, while the others, including appellant, pleaded not guilty. The Regional Trial Court (RTC) found appellant, Oliver, and Francisco, Jr. guilty of murder, acquitting the others due to lack of evidence. The RTC sentenced Oliver and appellant to reclusion perpetua and ordered them to pay civil indemnity and actual damages. Francisco, Jr.'s sentencing was suspended, and he was ordered to be placed under the care of the DSWD. On appeal, the Court of Appeals (CA) affirmed the RTC decision, modifying the award of damages and deleting actual damages. The CA gave credence to the testimonies of Ramon, Jr. and Rogelio, Jr., finding conspiracy and treachery. The CA did not give weight to Oliver's testimony exonerating appellant. Appellant filed a notice of appeal. The Petition: The Supreme Court reviewed the case on appeal.
Issue(s)
Whether the Court of Appeals erred in affirming the conviction of the appellant for murder. Whether conspiracy was sufficiently established. Whether the qualifying circumstance of treachery was present.
Ruling
The Supreme Court denied the petition, affirming the Court of Appeals Decision dated May 19, 2009, with modifications to the award of damages. Appellant Francisco Relos, Sr. was found guilty of murder and sentenced to reclusion perpetua, with modified awards for civil indemnity, moral damages, and exemplary damages.
Ratio Decidendi
On Issue 1: The Supreme Court found no reversible error in the assailed Decision. It held that findings of trial courts, especially when affirmed by the Court of Appeals, are accorded respect when no glaring errors or misapprehensions of fact are present. The Court sustained the factual findings of the trial court, as affirmed by the CA, particularly the weight given to the testimony of the victim's son, Ramon, Jr. The testimonies of Ramon, Jr. and other witnesses firmly established appellant's identity and participation in the killing. Therefore, Oliver's testimony that appellant was not at the scene was deemed a blatant lie. The Court affirmed the conviction of the appellant for murder. On Issue 2: The Supreme Court found that the finding of conspiracy was warranted. Conspiracy exists when two or more persons agree to commit an unlawful act and may be inferred from their conduct before, during, and after the crime, as well as from the mode and manner of the offense's perpetration. The synchronized acts of appellant, Oliver, and Francisco, Jr. in approaching the victim and delivering successive blows demonstrated their common objective to kill the victim. The Court reiterated that where conspiracy is shown, the act of one conspirator may be imputed to all, making each conspirator equally guilty as a co-principal. On Issue 3: The Supreme Court affirmed the trial court's finding that the crime was attended by treachery. Treachery is present when the means, methods, and forms of execution afford the victim no opportunity to defend himself or retaliate, and these were deliberately adopted by the accused without danger to themselves. The victim was distracted by Oliver's greeting and was caught off guard by the subsequent successive blows from the assailants. He was unarmed and had no opportunity to defend himself, thus establishing the presence of treachery.
Main Doctrine
Where conspiracy is shown, the act of one conspirator may be imputed to all, and the precise modality or extent of participation of each accused becomes secondary. Treachery is present when the attack is swift, unexpected, and gives the victim no opportunity to defend himself or retaliate, and such means were deliberately adopted without danger to the assailant.