G.R. No. 125896 - People vs. Sullano

On or about March 19, 1994, an altercation occurred during a wake for Cipriano Veloso held in Barangay West Timawa, Zone II, Molo, Iloilo City.
The accused-appellant, Steve Sullano, and another resident, Angelo Orillo, were present along with other local residents engaging in customary games at the wake.

The victim, Felix Villaruel, arrived at the wake appearing intoxicated.
An initial exchange occurred when Sullano, who was watching a card game, interacted with Villaruel:

Sullano instructed his nephew, known only as “Burnog,” to go home, threatening him with physical harm if he refused.
A verbal confrontation ensued between Villaruel and Angelo Orillo, initiated by greetings that escalated into threats.

As Sullano went to use the toilet, he encountered Villaruel again; an exchange about familiarity and presence led to further tension.
Sullano attempted to pass by the victim, but when Villaruel refused, a physical altercation broke out:

Sullano grabbed Villaruel as the latter tried to block his passage.
A fight ensued with Sullano delivering punches and kicks, sending the victim to the ground.

During the melee, witness Morito Dingcong testified that Sullano continued to maul Villaruel with repeated fist blows while Orillo simultaneously assisted by holding the victim’s arm.
Following the initial assault and amidst the commotion, the victim’s father, Jose Villaruel, arrived at the scene and shouted, “Hey, what are you doing to my son?”
Both accused initially fled the scene; however, subsequently, Angelo Orillo returned armed with a knife—allegedly provided by Sullano—and stabbed Felix Villaruel in the left chest.
The stabbing inflicted a fatal wound as confirmed by the autopsy report detailing a penetrating chest injury that perforated the cardiac structures and lung, resulting in massive hemorrhage.
Post-incident, while Orillo remained at large, Sullano was eventually arrested on July 3, 1994, after a period of absence characterized by his presence in Lambunao and Sta. Barbara, Iloilo.

The prosecution’s evidence relied heavily on witness testimonies, including that of Barangay Captain Domingo Doronila:

Doronila testified that he observed the two accused standing under an illuminated electric post and saw Sullano hand a knife to Orillo as they fled.
His testimony, although given six months after the incident because of his travel to Manila, was deemed credible given his position and the clarity of his account.

Other witnesses such as Bienvenido Equibal provided accounts confirming the sequence—from the initial mauling by Sullano to Orillo’s subsequent stabbing of the victim.
The autopsy report substantiated the cause of death as hemorrhage secondary to the stab wound, corroborating witness accounts of the fatal encounter.

The Regional Trial Court, Branch 35 of Iloilo City, found Sullano guilty of murder and sentenced him to reclusion perpetua, imposing accessory penalties including indemnity payments for death, funeral, and burial expenses.
The trial court also recognized a conspiracy element, holding that there was an implicit concert of action between Sullano and Orillo.
The defense contested the conspiracy finding, arguing that Sullano’s involvement was limited to the initial physical assault and that, having not personally inflicted the fatal knife wound, he should be liable only for lesser injuries.
The accused further contested the credibility of witness Domingo Doronila, alleging his testimony was coached; however, this contention was rejected on the ground that credibility assessments reside with the trial court.

Whether sufficient evidence exists to establish a conspiracy between Steve Sullano and Angelo Orillo in the commission of murder.
Whether the act of handing over the knife by Sullano to Orillo adequately demonstrates a joint enterprise, despite the fact that Sullano did not personally deliver the fatal blow.

Whether the testimony of Barangay Captain Domingo Doronila, given months after the incident, could be deemed reliable and free from fabrication.
The weight accorded to witness accounts that indirectly linked Sullano to the fatal act through his actions during the melee.

Whether Sullano’s flight from the scene—followed by his prolonged absence from the area—is indicative of consciousness of guilt.
Whether his absence, under the guise of attending fiestas, can be imputed as an act of evading accountability.

Whether Sullano should be held liable for murder given that the fatal stab wound was inflicted by Orillo, despite Sullano’s active participation in the assault.
Whether the acts of mauling and the subsequent handover of a weapon render Sullano complicit in the conspiracy to kill.