Facts:

The case involves the People of the Philippines as the plaintiff-appellee against Lope Maralit and Romy Pasia, the accused-appellants, concerning the murder of Jaime Cordelin, a 63-year-old resident of Carmona, Cavite, which occurred on October 16, 1982. A criminal complaint was filed in the Municipal Court of Carmona against four individuals: Romy Pasia, Maning Mendoza, Pedro Pacheca, and Lope Maralit. Following the complaint, Romy Pasia surrendered to the authorities on November 15, 1982, while Maning Mendoza remained at large. Pedro Pacheca, who was in custody, died on November 9, 1982. Lope Maralit was initially at large but was later apprehended. Both Maralit and Pasia were charged with murder in an amended information and pleaded "Not Guilty" upon arraignment. The trial court acquitted Pasia on grounds of reasonable doubt but convicted Maralit of murder, qualified by treachery, sentencing him to reclusion perpetua and ordering him to pay damages to the victim&...

Facts:

1. Background of the Case:

• A criminal complaint was filed against four individuals—Romy Pasia, Maning Mendoza, Pedro Pacheca, and Lope Maralit—for the killing of Jaime Cordelin on October 16, 1982, in Carmona, Cavite.
• Romy Pasia surrendered to authorities, Maning Mendoza remained at-large, Pedro Pacheca died while in custody, and Lope Maralit was later apprehended.
• Maralit and Pasia were charged with Murder in an Amended Information. Pasia was acquitted, but Maralit was convicted of Murder qualified by treachery and sentenced to reclusion perpetua.

2. Prosecution's Version:

• The victim, Jaime Cordelin, had a land dispute with the International Realty Corporation, where Maralit, Pasia, Mendoza, and Pacheca were employed.
• On October 2, 1982, at around 7:00 A.M., the victim and his two sons, Bienvenido and Danilo Cordelin, were ambushed while on their way to their farm.
• The assailants, including Maralit, Pasia, Pacheca, and Mendoza, fired shots from an elevated area about 5 to 7 meters high. The victim was shot multiple times, resulting in fatal injuries.
• The police found seven empty shells of an M-16 armalite rifle and one empty shell of a .45 caliber pistol at the scene.
• The autopsy revealed multiple gunshot wounds, mostly at the back of the victim, indicating treachery.

3. Defense's Version:

• Maralit and Pasia claimed alibi, stating they were at work at the time of the incident.
• They presented attendance reports and testimonies from co-workers and the plantation manager to support their alibi.
• The Trial Court dismissed their defense, finding it uncredible.

4. Motive for the Crime:

• The victim had refused to sell or leave the land he was working on, which led to threats and prior acts of violence, including the burning of his huts and fruit-bearing trees by the accused and their associates.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Conspiracy: Conspiracy does not require direct evidence of a prior agreement. It can be inferred from the acts of the accused, their closeness of association, and their concurrence in the criminal objective. Maralit's presence at the scene, his prior threats, and his association with the assailants established his participation in the conspiracy.
2. Alibi: Alibi is a weak defense and cannot prevail over the positive identification of the accused by credible witnesses. The proximity of the crime scene to Maralit's workplace made it possible for him to be present at both locations.
3. Treachery: The attack was sudden and unexpected, with the victim shot from behind, ensuring no risk to the assailants. This qualifies the crime as Murder with treachery.
4. Penalty Modification: Due to the abolition of capital punishment under the 1987 Constitution, the penalty for Murder was adjusted to reclusion temporal in its maximum period to reclusion perpetua, with the Indeterminate Sentence Law applied.