G.R. No. 225640 - People vs. Acquiatan

The accused-appellant, Joel Acquiatan (“Kain”), along with co-accused Anthony Palada and Jonalyn Logrosa, was charged with the murder of Franco Anacio.
The crime occurred on February 1, 2009, at around 12 midnight in Brgy. 04, Can-Aavid, Eastern Samar, Philippines.
The information alleged that the accused, in concert and with treachery, malice afterthought, evident premeditation, and deliberate intent, attacked and fatally wounded the victim with a shotgun, causing his immediate death.

Marly Anacio, the wife of the victim, testified that while she, her husband, and their baby were sleeping, they were disturbed by their dogs barking.
Franco peered through a hole in the wall and saw four persons outside the fence. Later, after a gunshot was heard, Marly witnessed the accused-appellant, Palada, and Logrosa leaving the crime scene.
Eva Anacio, the victim’s mother, corroborated Marly’s account by stating that she saw the accused-appellant and his companions conversing and later fleeing immediately after hearing a gunshot.
SPO4 Feleo Grata, the investigating officer, confirmed the sequence of events by noting the physical evidence at the scene (a hole in the wall and the recovery of an empty shell from a homemade 12-gauge shotgun).

The witnesses’ observations placed the accused-appellant and his companions at the scene just before and immediately after the shooting.
Evidence included the recovery of a spent shell, the existence of a hole in the wall, and the Certificate of Death stating multiple gunshot wounds.

Prior threats were recorded, including Franco being warned by Palada on December 22, 2008, and an earlier incident on January 8, 2009, where the accused-appellant was involved with companions in a situation near the Iglesia ni Cristo Church.
The circumstantial evidence was used to infer that all those present had conspired to commit the murder even though no eyewitness identified who fired the fatal shot.

The accused-appellant testified that he was asleep in his house at the time of the incident, supported by his parents, sister, and a family friend, Wenefrida Cantos.
He stated that he had gone to sleep early on January 31, 2009, and awakened on the morning of February 1, 2009, only to learn of Franco’s death from a neighbor, Eustaquio Legion.

Wenefrida Cantos testified that she witnessed the accused-appellant at home, reinforcing his claim of being asleep during the incident.
Other co-accused, Palada and Logrosa, also advanced their respective alibis—asserting that they were in their cousin’s house or in Balanga City, respectively.

On July 1, 2014, the RTC convicted the accused-appellant of murder beyond reasonable doubt, while acquitting Logrosa due to insufficient proof.
The RTC imposed various damages on the accused-appellant, including indemnity, moral, and temperate damages, in addition to reclusion perpetua.

On March 28, 2016, the CA affirmed the RTC’s judgment with modifications, notably requiring the accused-appellant to pay exemplary damages apart from the damages already awarded.
The CA maintained that sufficient circumstantial evidence established that the accused-appellant and his co-accused conspired and acted in concert to kill Franco.

The prosecution argued that the actions of the accused-appellant and his companions, arriving together at the scene and fleeing immediately after the fatal gunshot, indicated a common design or conspiracy to murder.
The absence of a direct eyewitness for the actual shooting led to reliance on circumstantial evidence and inference of conspiracy.

Whether the circumstantial evidence presented was sufficient to establish the existence of a conspiracy among the accused beyond reasonable doubt.

Did the sequence of events and the testimonies unequivocally demonstrate that the accused-appellant and his co-accused acted with a common design to commit murder?

Whether each accused should be held liable only for his own overt acts or as a principal perpetrator under the doctrine of conspiracy.

Can mere presence at the crime scene without clear evidence of an overt act justify a conviction for conspiracy?

Whether the evidentiary standard of proof beyond reasonable doubt was met, particularly concerning the requirement for an overt act which transcends mere companionship at the scene.