Facts:

In the case of People of the Philippines vs. Rolando Tamayo, Julio Tamayo, Florencio Patalinghug, Jr., and Natividad Tamayo, the accused were charged with double murder before the Regional Trial Court of the Seventh Judicial Region, Branch 62, located in Oslob, Cebu. The information was filed on November 29, 1994, alleging that on October 25, 1994, at approximately 7:30 PM, the accused conspired to kill Leodegario Fuentes and his son Renante Fuentes in their home in Sitio Tubod, Cerdeña, Malabuyoc, Cebu. The prosecution's case was primarily based on the testimony of Lilia Fuentes, the wife and mother of the victims, who witnessed the attack. She recounted that three men, identified as Rolando Tamayo, Julio Tamayo, and Florencio Patalinghug, Jr., entered their home and shot her husband and son. After the incident, Lilia sought refuge with neighbors and reported the crime to the police two days later. The trial court found the accused guilty of double murder on September ...

Facts:

• Incident Details: On October 25, 1994, at Sitio Tubod, Cerdeña, Malabuyoc, Cebu, accused Rolando Tamayo, Julio Tamayo, Florencio Patalinghug, Jr., and Natividad Tamayo were charged with double murder for the shooting deaths of Leodegario Fuentes and his son Renante Fuentes. The attack occurred during dinner when the accused allegedly conspired, entered the victims' home, and shot them. Lilia Fuentes, the wife and mother of the victims, witnessed the incident and identified the accused.
• Prosecution’s Case: Lilia Fuentes testified that Rolando shot her husband and son, while Julio used a flashlight to illuminate the scene. Florencio was present but did not shoot. Dr. Danilo Cabigon confirmed the cause of death as gunshot wounds. The accused were arrested and charged.
• Defense’s Case: The accused denied involvement, claiming alibi. Natividad and Julio testified they were at home during the incident. Rolando claimed he was at a novena prayer, and Florencio stated he was at a family event commemorating his sister’s death anniversary.

Issue:

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Ruling:

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Ratio:

1. Credibility of Witness: Lilia Fuentes’ testimony was credible despite minor inconsistencies. Her identification of the accused was reliable due to sufficient lighting and proximity to the events.
2. Alibi Defense: Florencio’s alibi failed as it was not physically impossible for him to be at the crime scene. Positive identification by an eyewitness prevails over alibi.
3. Conspiracy Not Proven: The prosecution failed to prove beyond reasonable doubt that Florencio conspired with the other accused. Mere presence at the crime scene does not establish conspiracy.
4. Accomplice Liability: Florencio was found guilty as an accomplice because he knowingly aided the crime without directly participating in the shooting. His actions supported the principal actors but were not indispensable to the crime.
5. Qualifying Circumstances: Treachery was proven as the attack was sudden and unexpected, rendering the victims defenseless. Evident premeditation was not established.
6. Penalty: As an accomplice, Florencio’s penalty was one degree lower than that of the principals. He was entitled to the benefits of the Indeterminate Sentence Law.