GR 24780; (June, 1981) (Digest)
G.R. No. L-24780 June 29, 1981
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAYMUNDO ARAJA and RODING ARAJA, defendants-appellants.
FACTS
The accused-appellants, brothers Raymundo and Roding Araja, were convicted of Murder for the killing of Apolonio Aquino. The prosecution evidence established that on the evening of November 29, 1962, the victim, accompanied by friends including eyewitness Epifanio Umali, went to Barrio San Gabriel to serenade Gregoria Bathan, a cousin of the appellants. After the serenade, while the group was on the road, they heard shouts. When the victim beamed his flashlight toward the source, both appellants were seen armed and they simultaneously fired at him, causing fatal gunshot wounds. The victim’s ante-mortem statement and his father’s testimony corroborated the eyewitness account, identifying the appellants as the assailants and citing a motive related to the victim’s courtship of Gregoria.
The defense presented alibi, claiming they were elsewhere during the incident. They also challenged the credibility of the prosecution witnesses, suggesting the testimony was rehearsed and that the witness had motive to fabricate. The trial court found the prosecution’s evidence credible and convicted the appellants of Murder qualified by treachery, sentencing each to reclusion perpetua.
ISSUE
Whether the guilt of the appellants for the crime of Murder was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the testimony of eyewitness Epifanio Umali to be credible, natural, and consistent. His account of the sudden and simultaneous shooting by both appellants was corroborated by the victim’s dying declaration and the physical evidence. The defense of alibi was weak and could not prevail over the positive identification by the credible eyewitness. The Court upheld the finding of treachery (alevosia), as the mode of attack—a sudden and unexpected assault with firearms—ensured the execution of the crime without risk to the appellants from any defense the victim could offer. Evident premeditation was not proven. Aggravating circumstances like abuse of superior strength and nocturnity were absorbed by treachery. With no modifying circumstances, the penalty of reclusion perpetua was appropriate. The civil indemnity was increased to P12,000.00.