Arceno v. People

G.R. No. 116098 (April 26, 1996)

Facts:

On April 25, 1986, Bernardito P. Vencer was taken from his uncle's house in Barangay Calangag, Batad, Iloilo, by a group of armed men, including members of the Integrated National Police (INP) and the Philippine Constabulary (PC). The group, which included the petitioners, claimed they were conducting a military operation to arrest Bernardito, who was allegedly a notorious criminal. Witnesses, including Bernardito's uncle Bernardino Vencer and a local herbalist Fernando Aguasa, testified that they saw the group take Bernardito away without showing any warrant of arrest.

Later that night, after hearing gunshots, Bernardino and Aguasa learned of Bernardito's death. Edmundo Evangelio, another witness, testified that he saw the petitioners shoot and stab Bernardito in a hut where he was taken. The medical examination confirmed that Bernardito died from multiple gunshot and stab wounds.

The petitioners were charged with murder, and during the trial, they claimed they were acting in self-defense, asserting that they were ambushed by Bernardito and his companions. They also presented an alibi, particularly Zaldy Arceno, who claimed he was on guard duty at their headquarters during the incident.

Legal Issues:

1. Whether the Sandiganbayan erred in finding the petitioners guilty of murder.
2. Whether the testimonies of the prosecution witnesses were credible and sufficient to establish the guilt of the petitioners.
3. Whether the defense of self-defense and alibi presented by the petitioners was valid.

Arguments:

Prosecution:

• The prosecution presented eyewitness accounts that detailed how the petitioners took Bernardito and subsequently shot and stabbed him. The testimonies were consistent and corroborated by medical evidence.
• The prosecution argued that the actions of the petitioners constituted murder, as they acted with superior strength and without justification.

Defense:

• The petitioners contended that they were conducting a legitimate operation to arrest a criminal and that they acted in self-defense after being fired upon by Bernardito.
• Zaldy Arceno claimed he was not present at the scene, asserting an alibi based on his guard duty.

Court's Decision and Legal Reasoning:

The Sandiganbayan found the petitioners guilty of murder, emphasizing the credibility of the prosecution witnesses. The court noted that minor inconsistencies in their testimonies did not undermine their overall reliability. The court also rejected the self-defense claim, finding it implausible given the circumstances and the overwhelming evidence against the petitioners.

The court ruled that the petitioners acted in conspiracy, as they were armed and acted together in the commission of the crime. The defense of alibi was deemed insufficient, as it could not overcome the positive identification of the petitioners by multiple witnesses.

Significant Legal Principles Established:

• The credibility of witnesses is paramount, and minor inconsistencies do not necessarily negate their testimonies.
• Conspiracy can be inferred from the conduct of the accused before, during, and after the commission of the crime.
• The defense of alibi is the weakest defense and must be supported by corroborating evidence to be credible against positive identification.