This case clarifies that in a group attack, even if each assailant does not directly inflict all wounds, they are all liable if their actions collectively show a conspiracy to commit the crime. The Supreme Court affirmed the conviction of Lolito Honor and Alberto Garjas for two counts of murder, emphasizing that treachery was present, as the victims were given no opportunity to defend themselves. This ruling reinforces the principle that those who participate in a coordinated attack, with the intent to kill, will be held accountable for the resulting deaths, irrespective of who specifically inflicted each wound.

Sudden Violence: When a Drinking Spree Turns Deadly, Who is Responsible?

This case revolves around a tragic incident on February 3, 2001, in Ormoc City. After a drinking session, a group of men attacked Henry Argallon and Nestor Nodalo, resulting in their deaths, and injured Randy Autida. Lolito Honor, Alberto Garjas, Noel Suralta, and Pedro Tumampo were charged, though only Honor and Garjas were apprehended. The central legal question is whether Honor and Garjas were guilty of murder and frustrated murder, given conflicting testimonies and the actions of the other assailants.

The prosecution’s eyewitness, Rey Panlubasan, identified Honor and Garjas as the primary attackers. He stated that the victims were suddenly attacked after leaving a tavern, and the assailants stabbed them without warning. The medical evidence corroborated Panlubasan’s testimony, detailing the fatal stab wounds suffered by Argallon and Nodalo.

The defense argued that Panlubasan’s testimony contained inconsistencies, casting doubt on the identity of the attackers. However, the trial court found Garjas’s testimony partly corroborated Panlubasan’s account, weakening their defense of alibi. The Regional Trial Court convicted Honor and Garjas of murder but acquitted them of frustrated murder.

On appeal, the Court of Appeals affirmed the RTC’s decision with a modification, ordering both Honor and Garjas to pay moral damages to the victims’ families. Honor and Garjas then appealed to the Supreme Court, challenging the credibility of the eyewitness and arguing that the prosecution failed to prove their guilt beyond a reasonable doubt.

The Supreme Court emphasized the importance of the trial court’s assessment of witness credibility, noting its unique position to observe the demeanor of witnesses during trial. Minor inconsistencies in a witness’s testimony do not necessarily undermine their credibility; rather, they can be badges of truth. Panlubasan’s identification of the accused was deemed positive and credible.

Building on this principle, the Supreme Court found that the prosecution successfully established the element of treachery. Treachery exists when the attack is sudden and unexpected, leaving the victims unable to defend themselves. In this case, the victims were unarmed and walking home when they were abruptly attacked and stabbed. This treacherous nature of the attack qualified the crime as murder, according to Article 248 of the Revised Penal Code.

ART. 248. Murder. – Any person who, not falling within the provisions of Article 246, shall kill another, shall be guilty of murder and shall be punished by reclusion perpetua, to death if committed with any of the following attendant circumstances:

1. With treachery, taking advantage of superior strength, with the aid of armed men, or employing means to weaken the defense, or of means or persons to insure or afford impunity;

Furthermore, the Supreme Court addressed the issue of multiple deaths resulting from the attack. While the original information charged the accused with two distinct offenses of murder, the accused waived their right to be tried separately by failing to file a motion to quash. Thus, the Court held that the accused should be sentenced for two counts of murder.

The Supreme Court also addressed the issue of damages, holding the accused jointly and severally liable. In cases where death occurs due to a crime, the heirs of the victim are entitled to civil indemnity ex delicto, actual or compensatory damages, moral damages, exemplary damages, attorney’s fees, and interest. The Court awarded civil indemnity of P75,000 and moral damages of P50,000 to the heirs of each victim.

The Court reinforced that, under conspiracy, the act of one is the act of all, underscoring that each conspirator is liable for the acts of the others during the commission of the crime. The collective behavior of the group before, during, and after the stabbings revealed a common goal and the intent to bring about the victims’ death, thus solidifying the element of conspiracy among the accused. Alibi is a weak defense. To reiterate, positive identification by a witness is stronger evidence.

FAQs

What was the key issue in this case?	The key issue was whether Lolito Honor and Alberto Garjas were guilty of murder and frustrated murder based on the evidence presented by the prosecution, particularly the testimony of the eyewitness.
What is treachery in the context of murder?	Treachery is a circumstance where the offender employs means, methods, or forms in the execution of the crime that ensure its commission without risk to themselves and without giving the victim a chance to defend themselves.
What does ‘proof beyond reasonable doubt’ mean?	Proof beyond reasonable doubt means that the prosecution must present enough evidence to convince the court that there is no other logical explanation for the facts except that the accused committed the crime.
What is the penalty for murder under the Revised Penal Code?	Under Article 248 of the Revised Penal Code, murder is punishable by reclusion perpetua to death, depending on the presence of aggravating or mitigating circumstances.
What is the significance of an eyewitness testimony?	An eyewitness testimony is crucial in criminal cases as it provides a direct account of what the witness saw or heard during the commission of the crime, helping to establish the facts and identify the perpetrators.
What damages are awarded to the victim’s heirs in murder cases?	In murder cases, the victim’s heirs are typically awarded civil indemnity, moral damages, and sometimes exemplary damages, as well as compensation for actual losses and expenses.
How does the court assess the credibility of a witness?	The court assesses credibility by considering factors such as the witness’s demeanor, consistency of testimony, any potential bias, and corroboration of their statements by other evidence.
What is conspiracy in criminal law?	Conspiracy is an agreement between two or more persons to commit a crime, and the act of one conspirator is considered the act of all, making them all equally liable.
What happens if an accused waives their right to a separate trial for multiple offenses?	If an accused waives their right to a separate trial, they can be tried for multiple offenses in a single trial, and the court can render a verdict on each offense based on the evidence presented.

This case underscores the judiciary’s commitment to holding perpetrators accountable for violent crimes, especially when those crimes are committed with treachery and in conspiracy with others. It also serves as a reminder of the legal consequences for participating in group attacks that result in death.

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: PEOPLE OF THE PHILIPPINES, APPELLEE, VS. LOLITO HONOR Y ALIGWAY, ET AL., G.R. No. 175945, April 07, 2009