Title
People vs. Aranja y Arana
Case
G.R. No. 56268
Decision Date
Oct 13, 1989
Neighbors with a history of hostility; Gregorio Aranja convicted of murder for conspiring in the unprovoked stabbing of Joseph Tan, upheld by the Supreme Court despite alibi defense.

Case Summary (G.R. No. 56268)

Proceedings and Initial Rulings

The spouses were convicted by Judge Augusto M. Amores of the Court of First Instance of Manila for their respective roles in the murder, resulting in their sentences of life imprisonment. While both initially appealed the judgment, Magdalena later withdrew her appeal, leaving only Gregorio’s case for review before the higher court.

Testimonies and Evidence

Evidence presented during the trial included testimony from key witnesses. Lucilo Amora, a friend of the victim, described the attack in detail, identifying the assailants, including the Aranjas, and the sequence of events that led to Joseph Tan's fatal injuries. Ricardo Pretal heard Gregorio Aranja suggest a violent approach to dealing with disputes, and Bernabe Andres testified that Tan identified his attackers shortly after the incident.

Defense Arguments

In their defense, both Gregorio and Magdalena Aranja claimed no involvement in the murder. Magdalena acknowledged her presence at the scene but claimed she did not participate, while Gregorio stated he was asleep during the attack. Their daughter, Zenaida, provided additional support for their claims, indicating that her father was at home during the incident. Witness Benjamin Garcia also corroborated Gregorio’s alibi, asserting that he observed him sleeping during the altercation.

Trial Court's Findings

The trial court rejected the Aranjas' defenses, affirming their active participation in the conspiracy to murder Tan. The court held that Gregorio's act of restraining Tan while another assailant stabbed him, coupled with Magdalena's direct command to attack, clearly indicated their complicity. The judge emphasized the importance of a collaborative effort among the attackers in executing the crime, which fell under the definition of conspiracy.

Legal Analysis of Conspiracy and Participation

The court maintained that despite the omission of other alleged conspirators from the charges, the individual responsibility of Gregorio and Magdalena could not be diminished. The presence of conspiracy was sufficiently established, as all involved acted in concert, demonstrating clear intent and commitment to the violent act. The court reiterated that small inconsistencies in witness testimonies do not undermine credibility when the overall testimony is believable, especially in chaotic situations.

Verdict and Conclusion

The Supreme Court upheld the trial court's decision, affirming the conviction of Gregorio Aranja for murder, qualified

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