Case Summary (G.R. No. 247824)
Procedural History
• June 18, 2010 – Information for murder filed against Danilo and Orlando before RTC, Branch 67, Bauang, La Union.
• August 16, 2010 – Danilo arrested and arraigned; pleaded not guilty.
• November 4, 2013 – Orlando arrested and arraigned; pleaded not guilty.
• RTC Decision – Convicted both of Murder with abuse of superior strength and conspiracy; imposed reclusion perpetua without eligibility for parole; ordered damages.
• November 13, 2018 – Court of Appeals (CA) affirmed RTC decision but increased death indemnity and exemplary damages to ₱100,000 each.
• SC Decision – Appeal dismissed with modifications to awards and penalty conditions.
Facts
• March 29, 2010 – Danilo and Orlando hired Antonio’s tricycle to bring Danilo to his probation officer in Agoo.
• Later that day – All three stopped at a videoke bar (“inuman”), where they drank; Rhandy joined.
• Evening – They agreed to transport Rhandy’s companion to Barangay Pantar, then returned to the bar.
• Trip to Bagulin – Antonio drove them; en route he stopped, a fight erupted inside the tricycle.
• Assault – Danilo boxed Rhandy; Orlando choked and restrained him; Antonio or Danilo stabbed Rhandy, then a big stone was used on the head.
• Disposal – All three dumped Rhandy’s body and the knife into a ravine; later returned home together without reporting the crime.
• Medico-legal – Dr. Daciego found fatal blunt head injury and abdominal wound.
• Parents – Testified to funeral expenses and emotional distress.
Issues on Appeal
I. Whether the RTC erred by convicting appellants despite findings that Antonio delivered the stab wounds.
II. Whether Antonio’s testimony was so discredited as to invalidate the prosecution.
III. Whether conspiracy was properly recognized.
IV. Whether appellants’ denial warranted acquittal.
V. Whether all elements of Murder under Article 248, RPC, were proven.
VI. Whether the presumption of innocence and reasonable-doubt rule were violated.
Applicable Law
• 1987 Constitution – Presumption of innocence, due process.
• RPC Article 248 – Definition and qualifying circumstances of Murder (here, abuse of superior strength).
• RPC Article 8 – Conspiracy.
• Rule 133, Section 2 – Proof beyond reasonable doubt requires moral certainty.
• Jurisprudence –
– Conspiracy may be implied from conduct before, during, after the crime (People v. Evasco).
– Abuse of superior strength entails gross disproportionality between assailants and victim.
Trial Court Findings
• Credibility – RTC gave weight to common points in conflicting testimonies rather than absolute fidelity of any single witness.
• Conspiracy – Inferred from joint acts: traveling, assaulting, disposing of the body, and unified departure.
• Abuse of Superior Strength – Victim unarmed, outnumbered, attacked with knife and stone.
• Penalty – Reclusion perpetua without eligibility for parole (death penalty abolished).
• Damages – Death indemnity ₱75,000; moral ₱100,000; exemplary ₱50,000; costs and interest.
Court of Appeals Ruling
• Affirmed RTC conviction for Murder under Article 248.
• Conspiracy and abuse of superior strength upheld.
• Modified damages – Increased death indemnity and exemplary damages to ₱100,000 each.
Supreme Court Analysis on Conspiracy
• Standard – Conspiracy proven beyond reasonable doubt may be direct or implied.
• Implied conspiracy – Demonstrated by coordinated acts toward a single unlawful purpose.
• Application – Common conduct of appellants and Antonio (joint transport, no protest, shared disposal, unified departure) established implied conspiracy.
• Consequence – Acts of one conspirator are imputed to all, making individual delivery of death blow immaterial.
Supreme Court Analysis on Abuse of Superio
Case Syllabus (G.R. No. 247824)
Facts of the Case
- On March 29, 2010 in Naguilian, La Union, Orlando and Danilo Padilla hired tricycle driver Antonio Villanueva to bring them to Agoo for Danilo’s probation meeting and later to a videoke bar.
- At the bar, they encountered Rhandy Padin; after drinking together and a side trip to Barangay Pantar, they returned to continue their spree.
- Antonio agreed to drive them to Bagulin; at Upper Bimmotbot a fight erupted inside the tricycle.
- The brothers dragged Rhandy out, Danilo boxed and stabbed him with a knife, and Orlando restrained him.
- Antonio stayed in the tricycle until Danilo bent the knife and struck Rhandy’s head with a stone, causing fatal injury.
- All three disposed of Rhandy’s body and the knife in a ravine, then left together.
Procedural History
- June 18, 2010: Information for Murder filed against Danilo and Orlando.
- August 16, 2010: Danilo arrested; pleaded not guilty; trial commenced.
- November 4, 2013: Orlando arrested; pleaded not guilty; trial consolidated.
- November 13, 2018: RTC Branch 67, Bauang, La Union found both guilty of Murder (abuse of superior strength, conspiracy); imposed reclusion perpetua without parole; awarded damages.
- Court of Appeals affirmed (Feb. 23, 2022) with increased damages.
- Appellants elevated the case to the Supreme Court.
Version of the Prosecution
- Antonio’s eyewitness account: the Padilla brothers attacked Rhandy with intent to kill, using a knife and stone.
- Medico-legal findings: cause of death was blunt traumatic head injury; additional knife wounds present.
- Testimonies from Rhandy’s parents outlined the emotional impact and funeral expenses.
Version of the Defense
- Danilo claimed Antonio stabbed Rhandy after a fare dispute; denied joint attack or disposal.
- Orlando maintained he ran away upon hearing Antonio’s threat and did not join the assault or body disposal.
- Both denied any conspiracy or abuse of superior strength.
Findings of the Regional Trial Court
- Credited common elements