G.R. No. L-55687 - Juasing Hardware vs. Mendoza

An Amended Information dated 10 April 2012 charged Rommel Bermudo y Capistrano together with his co‑accused Ronelo Bermudo y Marcellano and Rolando Bermudo y Capistrano with the murder of Gilberto Bedrero.
The accusatory portion alleged that on 7 March 2012 at about 8:30 P.M. in Barangay San Francisco, Canaman, Camarines Sur, the accused, conspiring and mutually assisting one another while armed with deadly weapons, willfully and feloniously attacked and hacked Gilberto Bedrero resulting in multiple stab/hack wounds that led to his death.
During arraignment on 11 April 2012, both Rommel and Ronelo pleaded not guilty, while Rolando remained at large.

Earlier in the day at around 6:30 P.M., an argument occurred between Ronelo and Philip Bedrero, the victim’s cousin, regarding a damaged bike.
Following the initial altercation, at about 8:30 P.M. Ronelo, armed with a bolo, confronted Philip outside his house, demanding that he come out so Ronelo could kill him.
Gilberto Bedrero, father of Philip and husband to Lolita, intervened in an attempt to pacify Ronelo by promising to fix the bike the next day.
Suddenly, Rommel and Rolando rushed toward Gilberto:

Philip, attempting to help, was injured when Rommel swung the ax at him.
Grace Bedrero, Gilberto’s niece, witnessed the assault and tried to assist by cradling the bloodied victim but was ordered by Ronelo to step away.
Gilberto was eventually brought to the Bicol Medical Center where he succumbed to his injuries after several hours of treatment.
Medical findings later indicated that Gilberto died from a combination of cardio‑pulmonary arrest, hemorrhagic shock, and hack wounds, with additional autopsy findings suggesting asphyxiation by manual strangulation and a stab wound in the chest.

Rommel testified that on 7 March 2012 he was drinking with friends at around 5:00 P.M. at Jimmy PeAalosa’s house.
Later, at about 8:30 P.M., while on his way to a videoke session at his own house, he encountered the scene where Ronelo was challenging Philip with a bolo.
According to Rommel’s account, after a brief confrontation and a stone thrown by Philip hitting Ronelo, the altercation escalated with Gilberto emerging armed.
Rommel claimed that following the clash and after his arrival, Philip then challenged him, causing him to flee and later be identified at the police station.

In its 27 January 2014 judgment, the Regional Trial Court found Rommel guilty beyond reasonable doubt of murder.
The RTC highlighted the clear identification by prosecution witnesses—Philip and Grace Bedrero—and their detailed narratives illustrating the coordinated and conspiratorial nature of the attack.
It was found that the killing was attended by qualifying circumstances such as treachery and the use of superior strength.
The judgment sentenced both Rommel and Ronelo to suffer reclusion perpetua and ordered them to pay to the heirs of Gilberto various damages (civil indemnity, moral, nominal, exemplary damages, and attorney’s fees).
The case involving Rolando was ordered to be archived pending his arrest.

On 26 June 2015, the CA affirmed the RTC’s judgment with modification.
The appellate court reiterated that the trial courts’ assessment of the credibility of witnesses is accorded finality absent evidence of oversight or misapplication of facts.
The CA noted that the eyewitnesses’ testimonies—corroborated by physical evidence—clearly identified Rommel as one of the assailants.
Although Rommel contended against the credibility of the witnesses (alleging bias due to familial relationship and questioning their sobriety), the CA maintained that such factors did not materially affect the reliability of their identification.
As a modification, the CA increased the exemplary damages awarded to Gilberto’s heirs to P75,000.00, with all damages to accrue interest at a rate of 6% per annum.

The prosecution witnesses, Philip and Grace, provided detailed and consistent accounts that interwove their observations to demonstrate the sequence of the attack.
There was corroboration between the places and times indicated by the testimonies and the physical evidence of the crime.
The testimony regarding Philip’s alleged intoxication was noted but found insufficient to undermine his reliable identification of the assailants.
Legal precedents were cited to support the reliability of eyewitness testimony even when witnesses are relatives of the victim.

Whether accused-appellant Rommel Bermudo y Capistrano is guilty beyond reasonable doubt of committing murder as charged.
Whether the collective and coordinated actions of Rommel with his co‑accused established conspiracy and a unified intent to kill Gilberto Bedrero.

Whether the alleged inconsistencies in testimony—particularly concerning the observations made by Philip and Grace Bedrero—suffice to cast doubt on their identification of the accused.
Whether the witnesses’ familial relationship with the deceased compromised their credibility as purported by the defense.
Whether the noted physical evidence and medical reports effectively corroborated the testimonies despite remarks on alleged intoxication.

Whether the qualifying circumstances of treachery and the concept of abuse of superior strength were properly appreciated by the trial courts.
Whether the actions of the accused, taken together, fulfill the elements of murder and conspiracy as defined under the Revised Penal Code.