G.R. No. 177573 - People vs. Asis

The accused-appellants, Roberto Asis and Julius PeAaranda, were charged with the crime of Murder for the killing of Donald Pais.
The incident allegedly occurred on or about June 7, 1998, in Quezon City, Philippines, where the accused, along with unidentified accomplices, attacked the victim with a bladed weapon.
The attack was characterized by elements of premeditation, treachery, and the use of overwhelming force, leaving the victim with multiple fatal stab wounds.

According to the complaint and subsequent evidence, the accused-appellants and their cohorts assaulted Donald Pais by ganging up on him, with specific actions noted such as Julius PeAaranda placing his arm around the victim and Roberto Asis participating in the stabbing.
Eyewitness accounts reveal that the victim initially was seen standing or sitting, but later was found either lying prostrate or on the ground as the attack unfolded.
The medical report by Dr. Anthony Joselito Llamas confirmed multiple stab wounds inflicted on vital organs, establishing that the cause of death was due to these wounds.

The Regional Trial Court (RTC) of Quezon City, Branch 95, in Criminal Case No. Q-98-77356 rendered a decision on July 28, 1999, finding the accused guilty beyond reasonable doubt for Murder under Article 248 of the Revised Penal Code.
The RTC sentenced the accused-appellants to reclusion perpetua and ordered them to indemnify the heirs of Donald Pais with specified amounts for death indemnity and compensatory damages.
The state’s evidence was primarily based on the positive identification of the accused-appellants by eyewitnesses and the corroborative medico-legal findings.

Prosecution witnesses included Ma. Theresa Ramos and Clifford Magsanoc, among others, who provided detailed descriptions of the events, identifying the accused-appellants as key participants in the murder.
The witness testimonies, while exhibiting minor discrepancies—for example, differing accounts of the victim’s position (sitting versus prostrate)—unequivocally pointed to the involvement of the accused.
The medico-legal report, detailing the number, location, and severity of the stab wounds, supported the narrative of a group assault resulting in the victim’s death.
Defense witnesses, such as Jennifer Indat and Villamor Casillan, as well as the accused’s own accounts, attempted to establish an alibi claiming they were at home (or otherwise engaged) at the time of the murder.

Following the RTC decision, the case was elevated to the Court of Appeals, which on July 31, 2006, affirmed the RTC ruling in toto.
The appellate decision reiterated that the accused-appellants’ alleged alibi, claiming they were asleep at home, was insufficient as the geographical proximity to the crime scene and the eyewitness identifications negated this defense.
The evidentiary discrepancies raised by the defense were deemed minor and not material enough to overturn the conviction.

The court ordered the award of various damages to the heirs of the victim, including civil indemnity, moral damages, exemplary damages, and temperate damages, with an additional interest at the legal rate of 6% until fully paid.
The award was based on established jurisprudence regarding compensation for death resulting from a crime, where documentary evidence for some expenses (such as burial costs) was substituted with a reasonable presumptive amount.

Whether the trial court erred in giving full weight and credence to the apparently conflicting testimonies of prosecution witnesses Ma. Theresa Ramos and Clifford Magsanoc, specifically concerning the victim’s position during the attack.
Whether the noted inconsistencies in the descriptions (e.g., the victim sitting versus lying prostrate) were material enough to undermine the overall identification of the accused-appellants.

Whether the state’s evidence, including the eyewitness identifications and the medico-legal report, proved the guilt of the accused beyond reasonable doubt.
Whether the discrepancies in some witness statements, when reconciled, still establish the accused-appellants’ participation in the crime.

Whether the defense’s claim that the accused-appellants were at home (or otherwise indisposed) during the commission of the crime stands in light of evidence showing their proximity to the crime scene.
Whether it was physically impossible for the accused to be at the locus criminis, a necessary element for a successful alibi defense.