G.R. No. 225336 - People vs. Pilpa y Dipaz

An Information was filed against Aquil Pilpa y Dipaz (Pilpa) charging him with the murder of Dave Alde.
The case was tried at the Regional Trial Court (RTC) of Manila, Branch 18, where Pilpa was convicted of Murder beyond reasonable doubt.
The RTC’s Decision was subsequently affirmed by the Court of Appeals (CA) in its Decision dated June 8, 2015.
Pilpa then filed an ordinary appeal with the Supreme Court assailing the CA’s decision.

The incident occurred on August 23, 2003, around 8:00 in the evening, in the City of Manila on Quirino Highway, Pandacan.

Eyewitness Barangay Tanod Leonila Abuel, while in search of someone, encountered a group that included the victim Dave Alde, Carol, Eva, and two unidentified persons.
Shortly thereafter, a second group of five men appeared, including a man named “JR” and Pilpa.

“JR” stabbed Alde on the chest with a big knife.
Pilpa, positioned behind Leonila, attempted to stab Alde immediately after “JR” had already struck him.
Witness Leonila intervened by identifying herself as a Barangay Tanod, which Pilpa dismissed with a remark indicating indifference.
The victim, Alde, managed to escape momentarily with the help of a companion known as “Choy” who parried Pilpa’s thrust.
Pilpa and his group then fled the scene.

The wounded Alde was brought to the Ospital ng Maynila where he underwent emergency and subsequent operations.
Despite attempts at medical intervention, Alde succumbed to his injuries in the recovery room after surgery.
Pilpa was eventually apprehended after being identified by a police officer and later by the victim when brought to the hospital.

Pilpa alleged that on the night of August 23, 2003, he was at a billiard hall near his residence and left around 8:30 pm to go home.
He asserted that his presence at the scene post-crime was coincidental and due to his subsequent arrest along with “JR” Niepes.
Pilpa maintained that he had no personal connection with the victim, Dave Alde, and hence no motive or intent to kill him.
He denied any participation in the stabbing incident, insisting that he was mistakenly implicated by prosecution witnesses.

During trial, the RTC gave greater evidentiary weight to the positive identification made by four prosecution witnesses: Barangay Tanod Leonila, Evangeline Abuel, Carolina Asis, and the victim himself.
The RTC found that even though it was “JR” who inflicted the actual stab wound, the collective conduct of the assailants demonstrated a conspiracy.
Based on the element of treachery and the established conspiracy, Pilpa was convicted of Murder and sentenced to suffer reclusion perpetua without eligibility of parole.
The RTC also awarded damages to the heirs of the victim for civil, moral, and exemplary damages.

In its Decision, the CA affirmed the RTC’s findings regarding the elements of the crime, including the existence of conspiracy among the assailants.
The CA upheld the coercive inference of a common criminal purpose despite the absence of direct evidence of a formal agreement.
However, the CA modified the amount of damages, adding an additional actual damage award for expenses incurred for the wake and burial of the victim.

Whether the Supreme Court should overturn the CA’s finding on Pilpa’s guilt, given the defense’s contention that the prosecution failed to prove his involvement in the murder beyond reasonable doubt.

Whether the CA erred in concluding that a conspiracy existed among the assailants, particularly considering Pilpa’s limited active participation compared to “JR”, who delivered the fatal stab.

Whether the CA correctly found that the killing was attended by treachery, thereby upgrading the crime from Homicide to Murder.
Whether the evidence was sufficient to establish that the assailants deliberately adopted a mode of attack designed to neutralize the victim’s capacity to defend himself.