People v. Nazareno
REITERATIONFacts
The Antecedents: David Valdez, Roy Magallanes, and Roger Francisco attended a wake where they drank liquor with accused Chito Nazareno and Fernando Saliendra. A heated argument occurred between Magallanes and Nazareno, which was pacified. The following day, Nazareno and Saliendra approached David, Magallanes, and Francisco, telling them not to mind the previous night's altercation. Later that evening, Nazareno and Saliendra blocked the path of David, Francisco, and Aida Unos. Nazareno boxed Francisco, who fled, while Saliendra pursued him. Nazareno then hit David with a stick, and Saliendra struck David's head with a stone. David ran towards a gasoline station but was caught by Nazareno and Saliendra, aided by barangay tanods. As David fell, the barangay tanods continued the assault. David died on November 14, 1993, from massive intra-cranial hemorrhage secondary to a depressed fracture on his right temporal bone. Procedural History: The Office of the City Prosecutor of Manila charged Nazareno and Saliendra with murder. Saliendra remained at-large, so only Nazareno was tried. The Regional Trial Court (RTC) found Nazareno guilty beyond reasonable doubt of murder, qualified by abuse of superior strength and aggravated by treachery. The RTC sentenced Nazareno to reclusion perpetua and ordered him to pay damages. On appeal, the Court of Appeals (CA) affirmed the conviction for murder qualified by abuse of superior strength but found no treachery. The CA modified the award of damages. The Petition: The People of the Philippines appealed to the Supreme Court, questioning the CA's finding of no treachery and seeking affirmation of the RTC's decision.
Issue(s)
Whether or not Nazareno took part in a conspiracy to kill David. Whether or not a qualifying circumstance of abuse of superior strength attended the killing of David.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, finding Chito Nazareno guilty beyond reasonable doubt of murder qualified by abuse of superior strength. The penalty of reclusion perpetua was affirmed, and the award of damages was modified to P141,670.25 as actual damages, P75,000.00 as civil indemnity, P75,000.00 as moral damages, and P30,000.00 as exemplary damages.
Ratio Decidendi
On the issue of conspiracy: The Court held that conspiracy is proven when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. Their actions indicating close personal association and shared sentiment can prove its presence. Proof of prior meeting is not necessary as long as their acts manifest a common design and oneness of purpose. In this case, the concerted steps taken by Nazareno and Saliendra, from waiting for David and his companions to the chase and the assault, demonstrated a common purpose. Even though Saliendra may have delivered the fatal blow, Nazareno is liable under the principle that in conspiracy, the act of one is the act of all. The Court found the testimonies of Magallanes and Francisco to be cohesive and corroborated by the autopsy results, and minor inconsistencies strengthened their credibility by showing spontaneity. On the issue of abuse of superior strength: The Court affirmed the CA's ruling that the killing was qualified by abuse of superior strength. Abuse of superior strength occurs when aggressors purposely use excessive force, rendering the victim unable to defend himself, thereby creating an unfair advantage. Here, Nazareno and Saliendra were armed with a stick and a stone, respectively, while David was unarmed. They chased him even as he fled, and when they caught up with him, aided by barangay tanods, they exploited their superior advantage to knock him unconscious. The victim's death from a head fracture caused by these blows established the presence of this qualifying circumstance.
Main Doctrine
Conspiracy is proven by the concerted actions of the accused manifesting a common design and oneness of purpose, even without prior meeting. In conspiracy, the act of one is the act of all. Abuse of superior strength is present when aggressors use excessive force rendering the victim unable to defend himself, creating an unfair advantage.