G.R. No. 56268 October 13, 1989
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GREGORIO ARANJA y ARAÑA and MAGDALENA ARANJA y RAMIREZ, accused-appellants.

FACTS

The spouses Gregorio and Magdalena Aranja were convicted of murder for the killing of their neighbor, Joseph Tan. The two families had a history of hostility, including prior assault cases. On the night of July 2, 1978, at their compound in Sta. Cruz, Manila, a coordinated attack occurred. Prosecution witness Lucilo Amora testified that the Aranjas’ son, Roberto, first assaulted him. Gregorio Aranja and Roberto then pinioned Tan’s arms. Magdalena, standing nearby, shouted, “Saksakin mo na, Raul!” prompting Raul Nuñez to stab Tan in the stomach with a bolo. A fifth assailant, Prado Azurpado, struck Tan’s head with wood. The victim later died from his injuries.
The defense presented alibis. Gregorio claimed he was asleep inside his house during the incident, supported by a witness. Magdalena admitted presence but denied participation, claiming she merely witnessed the event. Their daughter testified she saw Tan box Nuñez but looked away, later hearing Tan call Nuñez’s name. The trial court rejected these defenses, finding the spouses acted in conspiracy with the others based on the direct, positive testimonies of prosecution witnesses.

ISSUE

Whether the accused-appellant Gregorio Aranja is guilty of murder based on conspiracy.

RULING

Yes, the Supreme Court affirmed the conviction. The Court upheld the trial court’s factual findings, which are accorded great respect on appeal absent a clear lack of substantial basis. The legal logic centered on establishing conspiracy through the overt acts of each participant. Gregorio’s act of pinioning the victim’s arms, directly enabling Nuñez to stab Tan, demonstrated concerted action toward the common purpose of killing. Magdalena’s shouted command to stab was a clear instigation, further evidencing their unity of design. These acts, witnessed by Lucilo Amora, constituted direct evidence of conspiracy, making each conspirator equally liable for the crime.
The defense of alibi was properly rejected as it could not prevail over the positive identification and credible narration of events by the prosecution witness. The Court also ruled that minor inconsistencies in testimonies, given the commotion, do not impair overall credibility. The failure to indict all known conspirators does not exonerate those duly charged and proven guilty. The killing was qualified by treachery (alevosia) because the attackers rendered the victim defenseless by holding his arms before the fatal stab, ensuring the act without risk to themselves. The penalty of reclusion perpetua was affirmed, with civil indemnity increased to P30,000.00.