Case Summary (G.R. No. 173791)
Facts of the Case
On or about November 26, 1996, at approximately 12:05 a.m., an altercation occurred under the C-5 Bridge in Makati City involving five individuals: the victim, Felix Olandria y BergaAo, and four others including the accused Pablo Amodia, Arnold Partosa, George Palacio, and Damaso Amodia. The accused were armed with a piece of wood and a bladed weapon and took advantage of their superior strength. They forcibly restrained and assaulted the victim by beating him on the head and stabbing him multiple times, inflicting mortal wounds that caused his death. Pablo was identified by eyewitnesses as one of those who held the victim’s arms during the assault.
Procedural History
Pablo was indicted for murder on February 28, 1997, and arrested on June 5, 1998. He filed a motion to quash the Information on grounds of mistaken identity and the staleness of the warrant, which the trial court denied. Pablo pleaded not guilty and was tried by the Regional Trial Court (RTC), Branch 38, Makati City, which found him guilty beyond reasonable doubt and sentenced him to reclusion perpetua with corresponding civil liabilities. Upon appeal, the Court of Appeals (CA) affirmed the conviction with modifications to the damages awarded. Pablo subsequently appealed to the Supreme Court.
Issues Presented
- Whether the guilt of Pablo Amodia for murder was proven beyond reasonable doubt.
- Whether conspiracy existed between Pablo and the other accused to hold him liable for murder.
- Whether the defense of alibi was sufficiently credible to exonerate Pablo.
Prosecution's Evidence and Eyewitness Testimony
Two eyewitnesses, Romildo Ceno and Luther Caberte, residents familiar with the accused and the victim, positively identified Pablo at the crime scene holding the victim's right arm while the stabbing occurred. Their testimonies, supported by the clear illumination near the altercation site and the witnesses' proximity, established Pablo’s participation. The medico-legal evidence showed three fatal stab wounds inflicted by a single-bladed, sharp-pointed instrument, one penetrating the heart. The autopsy confirmed hemorrhage as the cause of death, directly linked to the stab wounds. Additional testimony from the victim’s father substantiated funeral expenses.
Defense’s Version and Alibi
Pablo asserted alibi, claiming he was at his sister Elma Amodia Romero’s house and later at his brother Elias’s residence during the time of the stabbing. He alleged that he was tending to his brother’s children while Elias and his wife went to a clinic. Defense witnesses Elma and Elias corroborated parts of Pablo’s alibi, testifying to his presence at their homes during the relevant times. However, inconsistencies in their testimonies regarding exact times and continuous presence excluded the impossibility of Pablo’s presence at the crime scene. The defense was unable to prove physical impossibility of Pablo’s participation effectively.
Rebuttal Evidence
A neighbor, Amelita Sagarino, testified that Pablo was absent during the victim’s wake, but neighbors identified Pablo among those responsible for the killing, further undermining the defense’s alibi claim.
Trial Court and Court of Appeals’ Findings
The RTC convicted Pablo of murder based on the eyewitness accounts establishing his identity, role as a principal by direct participation, and conspiracy with co-accused. The court found aggravating circumstances of abuse of superior strength and use of means to weaken the victim’s defense. The CA affirmed the conviction but modified the awards of damages, increasing the awards for moral and exemplary damages and correcting the applicable penalty provision under the Revised Penal Code.
Supreme Court’s Analysis: Credibility of Eyewitnesses and Positive Identification
The Supreme Court gave great weight to the trial court’s factual findings, emphasizing the credibility and consistency of the eyewitness testimonies, the well-lighted night, and the familiarity of witnesses with Pablo and the victim. The Court rejected Pablo’s attempt to confuse identity with name discrepancies and found no reason to doubt the witnesses’ positive identification. The Court also noted that the defense’s attempts to discredit the witnesses failed, and the evidence firmly establishes Pablo’s participation in the crime.
Supreme Court’s Analysis: Defense of Alibi
The Court reiterated that alibi cannot overcome positive identification unless physical impossibility is clearly demonstrated. The defense failed to establish that Pablo’s presence at the crime scene was impossible, especially considering the proximity of the locations and the inconsistent alibi testimonies by Elma and Elias. The Court applied strict scrutiny to these familial testimonies due to potential kinship bias and found the temporal inconsistencies significant enough to question their truthfulness. The alibi thus did not merit acquittal.
Supreme Court’s Analysis: Conspiracy
The Court explained that conspiracy exists by an agreement, direct or implied, among two or more persons to commit a felony. Direct proof is seldom available; circumstantial evidence, including the manner and unity of actions during the commission of the crime, suffices. The coordinated attack — accused surrounding the victim, restraining him, and delivering fatal blows — demonstrated a clear unity of purpose and joint participation. The continued restraint by Pablo while the victim was being stabbed is indicative of conspiracy and shared criminal intention.
The Court upheld the principle that, under conspiracy, th
Case Syllabus (G.R. No. 173791)
Facts of the Case
- On or about November 26, 1996, in Makati City, the accused-appellant, Pablo Amodia, along with three others, conspired to murder Felix Olandria y BergaAo.
- The accused, armed with a piece of wood and a bladed weapon, used their superior strength and means to weaken the victim’s defense.
- The victim was violently beaten on the head and stabbed multiple times, resulting in mortal/fatal stab wounds causing death.
- Pablo was indicted via Information filed on February 28, 1997, and arrested on June 5, 1998; the other accused remained at large.
- Pablo moved to quash the Information on grounds of mistaken identity and stale warrant; motion denied.
- Pablo pleaded not guilty upon arraignment.
Prosecution Evidence
- Documentary and testimonial evidence established Pablo’s participation as one of the four assailants.
- Eyewitnesses Romildo Ceno and Luther Caberte testified seeing Pablo restraining the victim’s right hand while others inflicted fatal injuries.
- Both eyewitnesses were familiar with the accused and the victim, knowing them as neighbors.
- The crime scene was illuminated by nearby lampposts, enhancing opportunities for accurate identification.
- The victim was stabbed three times with a single-bladed sharp-pointed instrument, verified by Post-Mortem Examination conducted by Dr. Antonio Bertido.
- Fatal wounds included a chest wound penetrating the heart, and wounds on the stomach and pancreas.
- The victim’s cause of death was hemorrhage secondary to stab wounds.
- Prosecutors presented testimony regarding expenses incurred by victim’s family as a result of the death.
Defense Evidence
- Defense relied on the defense of alibi, submitting testimonial and documentary evidence.
- Pablo claimed to have been at his sister Elma Amodia Romero’s house and at his brother Elias’s house during the stabbing.
- Elma and Elias corroborated Pablo’s presence at their respective residences, asserting he could not have been at the crime scene.
- Allegation that Pablo’s real name was Pablito Amodia intended to cast doubt on eyewitness identity.
- Defense witnesses’ testimony indicated Pablo was occupied with family matters and attending to children while the crime took place.
- Defense asserted no proof of conspiracy; questioned timing and opportunity for Pablo’s involvement.
Rebuttal Evidence by Prosecution
- Amelita Sagarino testified she never saw Pablo at the victim’s wake, contradicting defense allegations.
- She clarified neighbors identified Pabling and Pablito Amodia as one and the same person implicated in the crime.
- Prosecution emphasized testimonies that consistently placed Pablo at the scene with other assailants.
RTC Ruling
- The Regional Trial Court found Pablo guilty beyond reasonable doubt of murder as a principal by conspiracy.
- RTC grounded its decision on eyewitness testimonies, forensic evidence, and lack of evidence supporting physical impossibility of presence at the crime.
- Imposed penalty was reclusion perpetua without aggravating or mitigating circumstances.
- Ordered payment of moral damages and reimbursement of funeral expenses to victim’s heirs.