G.R. No. 202039 - Simundac-Keppel vs. Keppel

On or about September 7, 1997, in San Mateo, Rizal, a violent altercation occurred involving members of the Asuela family and the Villanueva family.
The incident took place during a gathering at the Villanueva residence while they were celebrating Wilfredo Villanueva’s birthday.
Appellants—Marcos Asuela, Juanito Asuela, Alberto Asuela, Roger Asuela, and Teofilo aBoyeta Capacillo—were charged along with at-large accused Jun-jun Asuela and Miguel Asuela.

Two separate charges were filed: one for murder (targeting Wilfredo Villanueva) and another for frustrated murder (allegedly concerning the actions that injured Anthony Villanueva).
Prosecutors alleged that the accused acted in concert by using various weapons—a knife, a lead pipe, a pointed bamboo pole, and tear gas—to attack the victims.
The actions purportedly included stabbing, clubbing, and spraying tear gas, all carried out in a coordinated, conspiratorial manner.

Eyewitness testimonies of Anthony Villanueva, Hayen Villanueva, and Magdalena Villanueva detailed how the assailants ambushed Wilfredo.

Anthony, present at the scene, described the sequence in which his father was surrounded and attacked by the appellants.
Hayen corroborated by noting the use of tear gas and stab wounds inflicted upon her father from a distance.
Magdalena testified by observing the crime through a window, confirming the collective action against Wilfredo.

The testimonies established that the assailants employed greater numbers and superior physical force, emphasizing a common criminal design.
Medical evidence, including the autopsy report by Dr. Ma. Cristina B. Freyra, confirmed that Wilfredo sustained multiple wounds—some of which were fatal—and that the weapons involved were consistent with the actions described.

The medico-legal report revealed that Wilfredo Villanueva suffered a total of twelve wounds, with seven deemed fatal by the medical examiner.
Anthony Villanueva, who sustained injuries during the same incident, was treated with first aid; his injuries were classified as slight, with treatment lasting less than nine days.
Testimony from Dr. Jose Aladin Bongco supported that while Anthony’s wounds were potentially serious, the limited medical intervention indicated they did not reach fatal or grave proportions.

Appellants generally denied their involvement, with several asserting an alibi or claiming that the incident was the result of a personal altercation between Juanito Asuela and the deceased.

Juanito Asuela advanced a claim of self-defense, arguing that he had only reacted to an unprovoked aggression initiated by Wilfredo Villanueva.
Other appellants maintained that they were elsewhere at the time of the attack or that the commotion was confined to a dispute between Juanito and the victim.

The defense contended that the evidence did not conclusively show fatal or serious injuries, particularly in relation to Anthony Villanueva, thereby suggesting that charges of frustrated murder should not apply.

The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt, giving full credence to the coherent and consistent testimonies of the prosecution witnesses.
The RTC held that the evidence established a conspiracy among the accused and that the abuse of superior strength was evident from the concerted and excessive use of force.
The decision rendered separate convictions:

In Criminal Case No. 3366, the accused were convicted of murder against Wilfredo Villanueva and sentenced to reclusion perpetua.
In Criminal Case No. 3365, the accused were convicted of frustrated murder against Anthony Villanueva but ordered to serve a modified sentence of reclusion temporal, later adjusted to a conviction of slight physical injuries.

Whether the evidence presented by the prosecution was sufficient to prove beyond reasonable doubt that the accused committed the crimes charged, particularly in establishing the fatal nature of some wounds and the level of their collective participation.

Whether the trial court erred in rejecting the self-defense claim asserted by Juanito Asuela despite allegations of unlawful aggression.
Whether the uncorroborated alibi and denials presented by the other appellants should have been given greater weight against the affirmative testimonies of the prosecution witnesses.

Whether the evidence substantiated the element of conspiracy, demonstrating that the accused acted in concert with a common criminal intent.
Whether the testimony adequately demonstrated that the abuse of superior strength constituted a qualifying circumstance that warranted a conviction for murder in the case of Wilfredo Villanueva, and if such evidence was lacking in the case of Anthony Villanueva to justify a charge of frustrated murder.

Whether the injuries inflicted on Anthony Villanueva, which received only first aid treatment and lasted less than nine days, justified a charge of frustrated murder or should be classified as slight physical injuries under the law.