G.R. No. 84361 ; May 31, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ELANITO QUIJANO, EDWIN LAYOG, DANILO LAPINID and EDGAR GONZALES, accused-appellants.

FACTS

Accused-appellants were convicted of Murder by the Regional Trial Court of Cebu. The prosecution evidence established that on September 16, 1986, in Carcar, Cebu, appellants Elanito Quijano, Edwin Layog, Danilo Lapinid, and Edgar Gonzales went to the house of the victim, Abundio Baring. Quijano, the victim’s nephew, called for water. When Baring and his wife Quintina responded, Gonzales immediately stabbed Baring. Layog and Quijano held the victim while Gonzales continued the assault, resulting in Baring’s death from multiple stab wounds. Lapinid restrained Quintina, preventing her from shouting for help. Subsequently, Gonzales decapitated the body, and the group left with the head.
In the early hours of the following day, the four appellants, riding a tricycle in Mandaue City, were intercepted by a police officer who discovered Baring’s head in their possession. Their arrest followed. Separate extrajudicial confessions were executed by Layog and Lapinid with the assistance of their respective counsel. The defense presented an alibi, claiming they were in the area for a fiesta and to sell a speaker, and alleged their confessions were coerced.

ISSUE

Whether the trial court erred in convicting the accused-appellants of Murder, particularly in finding conspiracy and in admitting their extrajudicial confessions.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the conclusive proof of conspiracy and the validity of the confessions. Conspiracy was evident from the appellants’ coordinated actions: Quijano lured the victim, Layog and Quijano held him during the stabbing, Gonzales inflicted the fatal wounds, and Lapinid controlled the witness. This unity of purpose and design established their collective criminal liability, making the act of one the act of all.
Regarding the extrajudicial confessions, the Court found them admissible and voluntary. The records showed Layog and Lapinid were assisted by counsel—Atty. Flavio Vargas and Atty. Avelino Escubido, respectively—who were present and signed the documents. The appellants’ bare allegations of force and intimidation, unsupported by evidence, were insufficient to invalidate the confessions. The findings of the trial court on witness credibility and the existence of conspiracy, being based on the evidence, were accorded finality. The penalty of reclusion perpetua was sustained, with the civil indemnity increased to Fifty Thousand Pesos.