G.R. No. 180986 - Altres vs. Empleo

On December 26, 1989, at around 8:00 o’clock in the evening, an altercation occurred at Sitio Alindayo, Almaguer North, Bambang, Nueva Vizcaya.
The victim, Edgardo F. Hernandez, was attacked within the jurisdiction of the Honorable Regional Trial Court of Nueva Vizcaya, Branch 30.

The accused-appellants—Vicente Antonio, Manuel Antonio, and Romeo Antonio—joined in a coordinated attack against the victim.
T/Sgt. Wilfredo Bala, a member of the Philippine Army, was initially included as an accused but was later dropped due to the failure to secure a Presidential waiver of military jurisdiction.
The attack involved multiple modes of assault including boxing, kicking, and strangulation, with evident premeditation and the use of superior strength.

Zacarias Hernandez testified that he was returning home when he encountered the victim and later heard a gunshot; he saw T/Sgt. Bala with a rifle and was then pelted by stones by the accused.
Rosalinda Reyes recounted that she observed the accused-appellants’ coordinated assault—Manuel and Romeo taking turns boxing and kicking while Vicente strangled the victim.
Feliciana Napao corroborated the assault by identifying the three accused as the individuals who were mauling the victim.
Physical evidence at the scene included three pairs of sandals and an additional lone sandal, while the death certificate indicated asphyxia due to “strangulation and suffocation,” reinforcing the cause of death.

Accused-appellant Vicente Antonio asserted that he acted in self-defense during the encounter. His version of events involved a verbal confrontation and an exchange of blows using a shovel and stones.
Accused-appellant Manuel Antonio claimed an alibi, stating that he was at home at the time of the incident, though his location was in the same barangay as the crime scene.
The defenses also attempted to challenge the credibility of the eyewitnesses and contended that any discrepancies in the testimonies (such as the exact number of stones thrown or the precise actions of T/Sgt. Bala) created reasonable doubt.

The Regional Trial Court found all accused-appellants (Vicente, Manuel, and Romeo Antonio) guilty beyond reasonable doubt of the crime of murder, emphasizing the aggravating circumstance of “nighttime.”
The court sentenced them to reclusion perpetua and imposed additional penalties, including the payment of actual damages, moral damages, and attorney’s fees to the heirs of the victim.
Notably, although Romeo Antonio was initially convicted, he escaped before the promulgation of the sentence.

The trial court accorded great weight to the testimonies of eyewitnesses including Zacarias Hernandez, Rosalinda Reyes, and Feliciana Napao, despite minor discrepancies in details.
It was determined that the collective actions of the accused-appellants demonstrated a conspiring effort and abuse of superior strength, thereby qualifying the crime as murder.
The lower court rejected the defenses of self-defense, alibi, and the claim of voluntary surrender, basing its decision on both testimonial and physical evidence presented during trial.

Whether the trial court erred in giving full credence to the identification and descriptions rendered by Zacarias Hernandez, Rosalinda Reyes, and Feliciana Napao.
Whether any uncertainties in the witness accounts (e.g., the number of stones thrown, the involvement of T/Sgt. Bala throughout the attack) should have undermined their overall reliability.

Whether the coordinated actions of the accused-appellants amounted to a conspiracy, thereby making each participant liable for the entire conspiracy even if their individual contributions varied (i.e., boxing/kicking by Manuel and Romeo, strangulation by Vicente).
Whether the acts committed collectively could render the individual acts as part of a unified criminal design.

Whether Vicente Antonio’s claim of self-defense holds merit given that he was one of the principal aggressors in the incident.
Whether his account of a confrontation and subsequent physical struggle meets the legal threshold for self-defense.

Whether Manuel Antonio’s claim of being at home was effectively proven, particularly in light of his residence being in the same barangay as the crime scene.
Whether the alibi defense could negate the prosecution’s direct eyewitness identifications.

Whether the mitigating circumstance of voluntary surrender should be recognized, especially since the accused had already been effectively apprehended before any voluntary surrender took place.