G.R. No. 80762 - People vs. Gonzales

On October 31, 1984, the RTC of Iloilo, Branch 38, found all accused (except Rogelio Lanida) guilty beyond reasonable doubt of murder under Art. 248 RPC. They were sentenced to 12 years and 1 day to 17 years and 4 months of reclusion temporal, ordered to indemnify the heirs of the victim P40,000, awarded moral damages of P14,000, and to pay costs.
All accused (except Lanida) filed notices of appeal. Before the CA decision, all except Custodio Gonzales, Sr. withdrew their appeals to pursue parole.

On February 21, 1981 at about 9:00 PM, spouses Augusto and Fausta Gonzales surrendered to Barangay Captain Bartolome Paja, claiming Fausta had killed their landlord, Lloyd Penacerrada. They were brought to the Ajuy police sub-station.
Patrolman Salvador Centeno and Paja’s nephew returned to Sitio Nabitasan that night, saw the victim’s body in the bedroom, and Centeno made a rough sketch. The next morning (Feb. 22) Centeno and a photographer took more detailed photographs.
On February 22, 1981 at around 11:20 AM, Dr. Jesus D. Rojas performed the autopsy at Ajuy Municipal Hall. He found 16 wounds (4 puncture, 7 stab, 4 incised, 1 lacerated), five of which were fatal (penetrating heart, lungs, intestines). Cause of death: massive hemorrhage due to multiple wounds.

On February 23, 1981, Augusto Gonzales surrendered for protective custody.
On August 26, 1981, the Provincial Fiscal filed an Information for murder vs. Augusto and Fausta Gonzales, alleging conspiracy with four unknown persons, treachery, and evident premeditation.
On September 16, 1981, the spouses pleaded not guilty.
On October 6, 1981, Jose Huntoria volunteered as an eyewitness. After reinvestigation, an Amended Information (March 3, 1982) added four more accused: Custodio Gonzales, Sr. (appellant), Custodio Gonzales, Jr., Nerio Gonzales, and Rogelio Lanida; all pleaded not guilty.

Prosecution witnesses: Dr. Rojas (autopsy), Brgy. Capt. Paja (surrender), Patrolman Centeno & Corporal Sazon (investigation), P.C. operatives Belicanao & Palomo, eyewitness Huntoria, and Nanie Penacerrada (widow, damages).
Huntoria testified that on Feb. 21, 1981 at about 8:00 PM he hid 15–20 m away behind banana trees near a “linasan,” saw all six accused take turns stabbing/hacking the victim by moonlight, but could not say who did what act or with which weapon. He delayed reporting out of fear and later volunteered testimony out of conscience and because he was a tenant of the deceased.
Defense: appellant Custodio Gonzales, Sr. claimed alibi—he was asleep in his house about 1 km away and only learned of the killing from his grandchildren. All accused except Fausta (who admitted killing in defense of honor) denied participation.

The RTC convicted all accused based on Huntoria’s testimony and disregarded alibi.
The CA modified appellant’s penalty to reclusion perpetua (maximum for murder, no aggravating/mitigating circumstances), reduced indemnity to P30,000, affirmed conviction, and certified the case to the Supreme Court.

Whether the prosecution’s evidence, particularly eyewitness Huntoria’s testimony and the appellant’s alibi defense, proved Custodio Gonzales, Sr.’s guilt beyond reasonable doubt.
Whether the lower courts erred in sentencing the appellant to reclusion perpetua.