Facts:

The case involves the appeal of Francisco Coricor and Jose Glore against the decision of the Court of First Instance of Leyte, which convicted them of murder. The incident occurred on April 29, 1947, in the barrio of Tunga, Barugo, Leyte. On that day, Coricor and Quintin Ligutan approached Manuel Arpon, who was fixing a faucet at his store, and opened fire on him. Prior to this, Primo Obsequio and Victorino Brun had visited Arpon's wife, Salvacion Penaranda, inquiring about their daughter’s school attendance. After the shooting, Salvacion witnessed Coricor, Glore, Macul, and Brun firing at the store from the street. Manuel Arpon succumbed to his injuries shortly after the attack, with multiple gunshot wounds identified by the medical examiner. The prosecution presented evidence of a prior threat made by Glore against Arpon, indicating a motive for the attack. The trial court acquitt...

Facts:

Incident Overview:
On April 29, 1947, around 2:00 PM, in Barrio Tunga, Municipality of Barugo, Leyte, Manuel Arpon was fatally shot while fixing a barrel tap in his store. His wife, Salvacion Penaranda, witnessed the events.

Initial Interaction:
Primo Obsequio and Victorino Brun approached the store and asked Salvacion if their daughter Caridad would attend school. After Salvacion confirmed, they left.

Shooting Incident:
Immediately after their departure, Francisco Coricor and Quintin Ligutan suddenly appeared and fired shots at Manuel Arpon, causing him to collapse. Salvacion saw Jose Glore, Clemente Macul, Primo Obsequio, and Victorino Brun firing shots toward the store from the street. She instinctively lay face down. The assailants fled after the shooting. Manuel Arpon died 30 minutes later.

Autopsy Findings:
The autopsy revealed six wounds on Manuel Arpon’s body, including entrance and exit wounds from bullets, indicating multiple gunshot injuries.

Prior Threats:
In late March 1947, Jose Glore, accompanied by Robenta, Victorino Brun, Primo Obsequio, and others, had threatened Salvacion Penaranda, stating that he would settle his differences with her husband using a revolver.

Trial Proceedings:
The accused were charged with murder. The trial court acquitted Primo Obsequio, Victorino Brun, and Clemente Macul but convicted Francisco Coricor and Jose Glore, sentencing them to life imprisonment, joint and several indemnity of P2,000 to Manuel Arpon’s heirs, and a proportional share of the costs.

Issue:

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Ruling:

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Ratio:

1. Alibi Defense: An alibi defense fails when the accused is positively identified by credible witnesses. Francisco Coricor’s presence at the scene was confirmed, making his alibi untenable.
2. Treachery (Alevosia): Treachery exists when the attack is sudden and unexpected, ensuring the victim’s inability to defend themselves. The assailants’ coordinated actions and strategic positioning demonstrated this qualifying circumstance.
3. Conspiracy: Conspiracy does not require explicit agreement or participation in every act. It can be inferred from coordinated actions and shared criminal intent. Jose Glore’s prior threats and active participation in the shooting established his role as a co-conspirator, not merely an accomplice.