In Ureta v. People, the Supreme Court affirmed the conviction of the petitioners for murder and frustrated homicide, emphasizing the reliability of eyewitness testimony and the consequences of conspiracy. The Court underscored that when individuals act in concert with a common purpose, the act of one is the act of all, making each participant equally responsible for the resulting crime. Furthermore, the Court rejected the claim of self-defense, as the elements of unlawful aggression, reasonable necessity, and lack of sufficient provocation were not adequately proven. This ruling reinforces the principle that positive identification by a credible witness can outweigh defenses such as alibi and denial.

One Brother’s Testimony, a Web of Conspiracy: Unraveling the Truth in Ureta v. People

The case of Ureta v. People, with G.R. No. 135308, decided on August 15, 2002, revolves around a tragic incident in Bugasongan, Lezo, Aklan, where Jose Rocel Fulgencio was killed and his brother, Socrates Fulgencio, was injured. Benedict Ureta, Bernardo Taran, and Victor de Juan were accused of murder and frustrated homicide. The central question before the Supreme Court was whether the testimony of Socrates Fulgencio, the sole eyewitness, was sufficient to convict the accused beyond reasonable doubt, and whether the Court of Appeals correctly upgraded the conviction from homicide to murder.

The prosecution’s case heavily relied on the testimony of Socrates Fulgencio, who recounted the events of November 30, 1990. According to Socrates, he and his brother Rocel were ambushed by a group of men, including the petitioners. Socrates testified that Taran struck Rocel with a gun, de Juan stabbed him, and Ureta shot him with a long firearm. Despite the defense’s attempt to discredit Socrates’s testimony, the trial court and the Court of Appeals found him to be a credible witness.

The defense presented a different version of the events, claiming that Ureta acted in self-defense after Rocel allegedly pointed a gun at him. However, this claim was rejected by the courts. The trial court initially convicted the petitioners of homicide and frustrated homicide, but the Court of Appeals modified the decision, upgrading the conviction to murder based on the presence of abuse of superior strength and conspiracy.

The Supreme Court upheld the Court of Appeals’ decision, emphasizing the credibility of Socrates Fulgencio’s testimony. The Court noted that the trial court’s assessment of a witness’s credibility is entitled to great weight and respect, especially when affirmed by the appellate court. The Court also addressed the inconsistencies raised by the defense, stating that they concerned only minor and collateral matters and did not affect the essential elements of the crime.

The Court underscored the principle that credibility must be weighed not by the number of witnesses but by the quality of their testimonies. Socrates Fulgencio’s positive identification of the petitioners as among the perpetrators of the crime was deemed credible and consistent. The Court found no evidence of ill motive on Socrates’s part to falsely accuse the petitioners, further strengthening the reliability of his testimony.

As against the positive identification by Socrates Fulgencio, Taran and de Juan offered the defense of alibi and denial. The Supreme Court dismissed these defenses, reiterating that alibi is one of the weakest defenses and can easily be fabricated. The Court also noted that denial cannot prevail over the positive testimony of the prosecution’s eyewitness. The Court then addressed Ureta’s claim of self-defense, emphasizing that when an accused invokes self-defense, the burden of proof shifts to him to prove the elements of his defense by clear and convincing evidence.

The Court emphasized that three requisites must concur for a plea of self-defense to prosper: unlawful aggression, reasonable necessity of the means employed to prevent or repel it, and lack of sufficient provocation on the part of the person defending himself. The Court found that none of these elements were present in this case. First, there was no unlawful aggression on the part of Rocel against Ureta. Second, even assuming that Rocel had threatened to attack Ureta, the use of a gun by the latter to repel such an attack would not be reasonable. Third, there was no sufficient provocation on the part of Rocel before Ureta shot him.

The Court also addressed the issue of conspiracy, noting that the Court of Appeals found that conspiracy among the petitioners was amply established. The testimony of Socrates Fulgencio showed that the petitioners acted in concert, with each playing a role in the attack on Rocel. In conspiracy, the act of one is the act of all, and it is not necessary that all the participants deliver the fatal blow. With conspiracy duly established, all the petitioners were found guilty of murder for the death of Rocel Fulgencio.

The Supreme Court, in this case, discussed the requirements for proving conspiracy. It stated that conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. Direct proof is not essential to establish conspiracy; it can be inferred from the acts of the accused that show a common design to accomplish a criminal purpose. The Court highlighted that in conspiracy, the act of one is the act of all.

The Court also addressed the issue of the proper penalty for murder. Under Article 248 of the Revised Penal Code, murder is punished by reclusion perpetua to death. Both are indivisible penalties. However, since there was no aggravating circumstance, the penalty imposable in this case was reclusion perpetua. The Court also awarded moral damages to the heirs of the victim, in addition to civil indemnity.

Regarding the offense of frustrated homicide in Criminal Case No. 3323, wherein petitioner Benedict Ureta alone was charged for gunshot injuries inflicted on Socrates Fulgencio, the Court found Ureta’s defense of denial untenable. The Court concluded that Ureta’s defense to the charge of frustrated homicide was a mere concoction, deserving no serious consideration. The court then affirmed its decision:

The testimony of a single witness, when credible and trustworthy, is sufficient to sustain a conviction, even in a charge of murder and surely also in a charge of frustrated homicide. As earlier stated, we find the testimony of Socrates Fulgencio for the prosecution straightforward, convincing and entitled to full faith and credit. The conviction of petitioner Benedict Ureta in Criminal Case No. 3323 was properly sustained by the appellate court.

The Supreme Court, in Ureta v. People, reinforced several key principles of criminal law, particularly the weight of eyewitness testimony, the elements of self-defense, and the consequences of conspiracy. The decision highlights the importance of credibility in assessing witness testimonies and the stringent requirements for proving self-defense. It also underscores that when individuals act in concert with a common criminal purpose, each participant is equally responsible for the resulting crime, even if they did not directly perform the act that caused the victim’s death.

FAQs

What was the key issue in this case?	The central issue was whether the testimony of a single eyewitness, Socrates Fulgencio, was sufficient to convict the accused of murder and frustrated homicide, and whether the Court of Appeals correctly upgraded the conviction from homicide to murder. The court ultimately found the testimony credible and sufficient.
What is the significance of conspiracy in this case?	The Court of Appeals found that the petitioners acted in conspiracy, meaning they had a common purpose and design in committing the crime. In conspiracy, the act of one is the act of all, so all participants are guilty of murder even if they did not directly inflict the fatal wounds.
What elements must be proven for self-defense?	For a plea of self-defense to be successful, the accused must prove unlawful aggression on the part of the victim, the reasonable necessity of the means used to prevent or repel the aggression, and lack of sufficient provocation on the part of the person defending himself. In this case, the Court found that none of these elements were present.
What is the difference between homicide and murder in this case?	The Court of Appeals upgraded the conviction from homicide to murder due to the presence of abuse of superior strength. The victim, Rocel, was unarmed and attacked by a group of men armed with weapons, indicating that the attackers took advantage of their superior strength to commit the crime.
Why were the defenses of alibi and denial rejected by the court?	The defenses of alibi and denial were rejected because they were weak and easily fabricated. The positive identification of the accused by the eyewitness, Socrates Fulgencio, outweighed their claims of being elsewhere or not involved in the crime.
What was the penalty imposed on the petitioners?	The petitioners, Benedict Ureta, Victor de Juan, and Bernardo Taran, were found guilty of murder and sentenced to reclusion perpetua. They were also ordered to pay civil indemnity and moral damages to the heirs of the victim. Benedict Ureta was also found guilty of frustrated homicide and sentenced to an indeterminate penalty.
Can a single witness’s testimony be enough for a conviction?	Yes, the testimony of a single witness can be sufficient to sustain a conviction, even in a charge of murder or frustrated homicide, provided that the testimony is credible and trustworthy. The Court found Socrates Fulgencio’s testimony to be straightforward, convincing, and entitled to full faith and credit.
What is the significance of the medico-legal reports in the case?	The medico-legal reports provided crucial evidence regarding the nature and extent of the injuries sustained by the victims. These reports confirmed the gunshot wound on Socrates Fulgencio and the multiple stab wounds that led to the death of Jose Rocel Fulgencio.

The Ureta v. People case serves as a reminder of the critical role that eyewitness testimony plays in criminal proceedings, especially when corroborated by forensic evidence and when the witness is deemed credible. It also underscores the importance of understanding the legal elements of self-defense and conspiracy. The ruling clarifies that defenses such as alibi and denial will not prevail against positive identification by a credible witness. Furthermore, this case highlights the gravity of acting in concert with others to commit a crime, emphasizing that all participants will be held equally accountable.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Ureta v. People, G.R. No. 135308, August 15, 2002