G.R. No. L-61773. January 31, 1987.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALEJANDRO PARAS, EULOGIO PARAS, GREGORIO PARAS, ALBERTO PARAS, JUAN PARAS, and FRANCISCO VIRAY, accused-appellants.

FACTS

Accused-appellants, all members of the Paras family except Francisco Viray, were charged with Murder for the killing of Roseller Cayanan. The prosecution evidence established that on October 12, 1980, the victim was walking with Consolacion Manansala and her son Charlie when the appellants approached from behind. Alejandro and Eulogio Paras twisted the victim’s arms, rendering him helpless. Eulogio then struck Cayanan on the head with a hollow block, knocking him down. While the victim was prostrate, Alejandro stabbed him multiple times in the stomach and chest. Gregorio Paras also stabbed him, while Juan, Alberto, and Viray took turns hitting him on the head with hollow blocks and kicking him. The attack ceased only after Eulogio stated, “come on, let us go, anyway he is already dead.” The autopsy revealed six fatal stab wounds and severe head injuries.
The defense interposed alibi, claiming they were attending a relative’s funeral in another town at the time. They also denied conspiracy and argued the killing was frontal, negating treachery. The trial court convicted all accused present at trial (Viray remained at large) and sentenced them to reclusion perpetua, ordering them to pay indemnity and damages.

ISSUE

The primary issues are: (1) whether conspiracy and treachery attended the killing to qualify it as Murder; and (2) whether the defenses of alibi and denial should prevail over the positive identification by prosecution witnesses.

RULING

The Supreme Court affirmed the conviction, upholding the presence of conspiracy and treachery. Conspiracy was evident from the appellants’ coordinated conduct as a family unit, their simultaneous and sudden attack from behind, the collective infliction of fatal injuries, and their concerted flight upon Eulogio’s command. This collective action demonstrated a common purpose to kill. Treachery was properly appreciated because the mode of attack was deliberately adopted to ensure the execution without risk to the assailants. The victim was first rendered defenseless by having his arms twisted, then knocked down with a hollow block before being repeatedly stabbed and beaten. This method insured that the victim could not retaliate.
The Court rejected the defenses of alibi and denial. Alibi is inherently weak against the positive and credible identification by eyewitnesses Consolacion and Charlie Manansala, whose testimonies were consistent on material points. Minor inconsistencies in their accounts were deemed trivial and did not affect their credibility. The frontal nature of some blows after the victim was already subdued does not negate treachery, as the initial assault that incapacitated him was treacherous. The Court modified the civil liability, increasing the death indemnity to P30,000.00 in accordance with prevailing jurisprudence. The decision was affirmed with this modification.