Facts:

On September 27, 1987, Antonio Domingo was riding his bicycle along a deserted road in Barangay Coliling, Rosales, Pangasinan, when he was ambushed by a group of six men. The assailants brutally attacked him with a bolo, inflicting multiple stab wounds that ultimately led to his death. The attackers fled the scene, seemingly unaware that their actions had been witnessed. On February 23, 1988, an information for murder was filed against Catalino Lorioda, Igmedio Mortera, Alejandro Aguilar, Lorenzo Vinluan, Proceso Ancheta, and Lorenzo Marzan in the Regional Trial Court of Rosales, Pangasinan. However, Ancheta and Marzan were not arraigned as they remained at large. The four remaining accused pleaded not guilty. During the trial, the prosecution presented a key witness, Romeo Oganiza, who claimed to have witnessed the murder. Oganiza testified that he and another individual, Florencio Javien, were on their way to fetch Domingo when they observed the attack from a distance of ab...

Facts:

Incident Overview

• On September 27, 1987, Antonio Domingo was riding a bicycle along a deserted road in Barangay Coliling, Rosales, Pangasinan.
• He was waylaid by six men who hacked his head with a bolo and inflicted multiple stab wounds, causing his death.
• The attackers left the scene, unaware they had been observed.

Witness Testimony

• Romeo Oganiza, a prosecution witness, claimed to have witnessed the killing along with Florencio Javien.
• Oganiza testified that he and Javien were on their way to fetch Domingo when they saw the accused intercept him.
• They hid in a ditch approximately 30 meters away and observed the attack.
• Oganiza described the attack: Igmedio Mortera seized Domingo's right arm, Catalino Lorioda restrained him, Alejandro Aguilar hacked Domingo on the forehead with a bolo, and Lorioda, Lorenzo Vinluan, Lorenzo Marzan, and Proceso Ancheta took turns stabbing him.
• Domingo managed to free himself but died after walking about ten meters.

Reporting the Crime

• Oganiza and Javien immediately reported the killing to the Rosales police station, but Sgt. Valeriano Otoman refused to record their sworn statements or the names of the killers in the police blotter.
• They proceeded to the 151st PC Company in Tayug, Pangasinan, where their sworn statements were taken by T/Sgt. Danilo R. Pascua.
• Oganiza later claimed he was harassed and threatened by the Rosales police, forcing him to relocate to Simon, Pangasinan.

Defense of Alibi

• The four accused (Lorioda, Mortera, Aguilar, and Vinluan) pleaded not guilty and presented alibis.
  • Mortera and Aguilar claimed they were in Villasis, Pangasinan, at the time of the crime, borrowing money from Rafael Bascos and having coffee with Sgt. Otoman at Virgie's Canteen.
  • Lorioda and Vinluan claimed they were attending the wake and burial of Mamerto Advento in Rosales.
• Their alibis were corroborated by Bascos, Otoman, Lilia Darimbang (canteen owner), and Adriano Javien.

Trial Court Decision

• On April 19, 1990, Judge Manuel D. Victorio found all four accused guilty of murder.
• They were sentenced to reclusion perpetua and ordered to pay P30,000.00 in civil indemnity to the victim's heirs.

Issue:

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Ruling:

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Ratio:

1. Credibility of Witnesses:

   • The trial court's assessment of witness credibility is entitled to great respect and should not be disturbed on appeal unless shown to be arbitrary or disregarding essential issues.
   • Romeo Oganiza's testimony was found credible, candid, and spontaneous. He had no improper motive to falsely accuse the defendants.
   • The trial court observed that Oganiza could easily identify the accused as they were residents of the same barangay.

2. Defense of Alibi:

   • The alibi presented by the accused was unconvincing.
   • Mortera and Aguilar could have easily traveled from Villasis to Rosales, the crime scene, as the two locations are only a few kilometers apart.
   • Lorioda and Vinluan were in Rosales at the time of the crime, making their alibi weak.
   • The corroborating witnesses for the defense appeared biased and likely perjured themselves to support the accused.

3. Conspiracy and Motive:

   • The concerted attack on Domingo demonstrated a conspiracy among the accused to kill him.
   • Motive is not an essential element of murder and need not be proven when the crime and participation of the accused are clearly established.
   • Positive identification by an eyewitness (Oganiza) holds strong prosecutorial value, rendering motive irrelevant.

4. Penalty and Civil Indemnity:

   • The crime was qualified by abuse of superior strength, warranting the penalty of reclusion perpetua.
   • The civil indemnity was increased to P50,000.00 to align with current judicial policy.

Conclusion:

The Supreme Court upheld the trial court's decision, finding the accused guilty of murder based on credible eyewitness testimony and rejecting their alibi defense. The penalty of reclusion perpetua was affirmed, and the civil indemnity was increased to P50,000.00.