G.R. No. 196735. August 03, 2016 (Case Brief / Digest)

### Title:
**People of the Philippines v. Danilo Feliciano, Jr., Julius Victor Medalla, Christopher Soliva, Warren L. Zingapan, and Robert Michael Beltran Alvir**

### Facts:
This case revolves around the deadly consequences of fraternity-related violence which led to the murder of Dennis Venturina and the attempted murder of other students (Leandro Lachica, Arnel Fortes, Mervin Natalicio, Cristobal Gaston, Jr., and Cesar Mangrobang, Jr.) at the University of the Philippines (UP), Diliman. The altercation occurred on December 8, 1994, involving members of the Sigma Rho Fraternity.

The prosecution’s evidence centered on the credible and consistent testimonies of the victims and witnesses, who experienced or observed the violent episode. Despite wearing masks or disguises, the attackers were identified by the victims. The trial court initially found all the accused guilty beyond reasonable doubt, imposing the death penalty.

The case made its way to the Supreme Court on automatic review, shifting to the Court of Appeals following the Supreme Court’s directive in People v. Mateo to intermediate appellate review for such cases. The Court of Appeals upheld the convictions for murder but modified the conviction for the attempted murders to slight physical injuries, adjusting the penalties accordingly.

Dissatisfied, the accused-appellants filed separate motions for reconsideration to the Supreme Court, arguing on various grounds including the credibility of witness testimonies, the sufficiency of the information filed, and the alleged delay and procedural issues in reporting the crimes.

### Issues:
1. Whether the eyewitness testimonies were credible and consistent enough to identify the accused-appellants as the perpetrators.
2. Whether the Information filed violated the accused-appellants’ constitutional rights to be informed of the nature and cause of the accusation against them.
3. The credibility given to the testimonies of the UP Police Officers and the delay in reporting the incident.
4. The validity of the conspiracy among the accused-appellants as established by the trial court and upheld by the appellate courts.

### Court’s Decision:
The Supreme Court denied the motions for reconsideration, affirming its original decision with modifications regarding the penalties and damages awarded. The Court held that:

1. The identification of the accused-appellants by the victims and witnesses was credible and positive, despite arguments against it. This identification was sufficient to establish guilt beyond a reasonable doubt.
2. The Information sufficiently informed the accused of the nature and cause of the accusations against them, not violating their constitutional rights.
3. The arguments regarding the credibility of certain testimonies and the delay in reporting the incident were not persuasive enough to merit reconsideration.
4. The concept of conspiracy was applicable, as the participation and presence of the accused-appellants during the crime were evident, supporting the trial court and the Court of Appeals’ findings.

### Doctrine:
The Supreme Court reiterated that the testimony of a single witness, if credible and positive, could be enough to prove guilt beyond a reasonable doubt. It also reinforced the principle that an accused’s right to be informed of the charges against them is fundamental, but the sufficiency of an Information is determined by whether it adequately details the crime and any aggravating circumstances to enable the preparation of a defense.

### Class Notes:
– **Credibility of Witnesses**: The Supreme Court affirms the principle that the credibility of witnesses is a factual matter best left to the discretion of the trial judge, who has the advantage of observing the witness’s demeanor.
– **Information Sufficiency**: An Information must convey enough details to inform the accused of the nature and cause of the accusation (Rule 110, Section 6 of the Rules of Criminal Procedure).
– **Conspiracy**: The presence of conspiracy requires that the participants perform specific acts with a shared criminal intent or objective. The acquittal of some participants does not negate the presence of a conspiracy among those found guilty.
– **Right to be Informed**: An accused’s right to be informed of the charges against them is crucial for the preparation of the defense. This ensures fairness in the criminal justice process.

### Historical Background:
This case highlights the persistent issue of fraternity-related violence within Philippine universities, illustrating the challenges in addressing such violence despite institutional efforts and legal proceedings. The cultural norm and practices within fraternities, including the “code of silence,” significantly complicate the prosecution of related crimes.


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