Bug-atan vs. People of the Philippines

A co-conspirator's plea of guilty to a lesser offense in a separate criminal information does not benefit co-conspirators charged in a different information.

On April 14, 1993, Manatad and Bug-atan approached Maramara, providing him with a .38 caliber revolver, P500.00, and a promise of P30,000.00 plus the dismissal of a pending murder case against him, in exchange for killing Pastor Papauran. The following morning, Maramara and Labandero proceeded to the victim's house in Mandaue City while Bug-atan waited on a motorcycle nearby as backup. Maramara shot the unarmed victim in the head from behind. Three days later, Bug-atan and Maramara confirmed the victim's death. Maramara was arrested on April 21, 1993, and executed an extrajudicial confession implicating the petitioners.

• The Inducement: On April 14, 1993, Manatad and Bug-atan met with Maramara and instructed him to kill Pastor Papauran. They provided him with a .38 caliber revolver with three reserve bullets and P500.00 for transportation. They offered P30,000.00 and promised that Bug-atan would secure the dismissal of a separate murder case pending against Maramara.
• The Execution: On the morning of April 15, 1993, Maramara met with Bug-atan and Labandero. Maramara and Labandero took a jeepney to the victim's house in Labogon, Mandaue City, while Bug-atan followed on a motorcycle to act as backup. Maramara shot the victim once in the head, after which he and Labandero fled.
• The Confession and Arrest: Three days later, Bug-atan and Maramara returned to confirm the victim's death. Bug-atan instructed Maramara to keep silent and promised payment on April 21, 1993. Maramara was arrested on that same date and subsequently executed an extrajudicial confession detailing the conspiracy and implicating the petitioners.
• Defense Version: Petitioners denied the accusations. Manatad claimed he was faith-healing in other municipalities in Cebu from April 11 to 15, 1993. Labandero claimed he was in Manila due to death threats related to his testimony in a prior case against Maramara. Bug-atan simply denied participation. The defense attempted to impute ill motive to Maramara, noting Labandero had previously testified against him and Bug-atan had caused his arrest.

• Procedural Irregularity: Petitioners argued that Maramara's plea bargaining and conviction in Criminal Case No. DU-3721 were precipitately done following a skewed procedure, and that the separate filing of his case and theirs was improper.
• Credibility of Co-Conspirator: Petitioners maintained that Maramara was not a credible witness due to inconsistencies between his extrajudicial confession and court testimony, his questionable reputation, and his prior conviction. They ascribed ill motive to him, alleging revenge because Labandero had testified against him in a prior case and Bug-atan was responsible for his arrest.
• Lack of Conspiracy and Reasonable Doubt: Petitioners argued that conspiracy was not proven and their guilt was not established beyond reasonable doubt, asserting that their respective alibis and denials should be given weight over the testimony of a polluted source.

• Credibility of Testimony: Respondent countered that Maramara's testimony was credible, given in a straightforward manner, and corroborated by the medical findings regarding the location of the victim's wound.
• Existence of Conspiracy: Respondent argued that the concerted acts of the petitioners before, during, and after the killing demonstrated a common design to exterminate the victim.
• Rejection of Alibi and Denial: Respondent maintained that petitioners' alibis were not physically impossible and their bare denials crumbled in the face of positive identification by the prosecution's principal witness.

• Credibility of Co-Conspirator: Whether Maramara is a credible witness despite his prior conviction, alleged inconsistencies, and ascribed ill motive.
• Conspiracy: Whether conspiracy among the petitioners was proven beyond reasonable doubt.
• Procedural Validity and Effect of Plea Bargaining: Whether the proceedings in Maramara's separate case were procedurally flawed and whether his plea bargain to homicide benefits the petitioners.
• Proper Offense and Penalty: Whether the crime committed was homicide or murder, and the corresponding penalty given the attending circumstances.

• Credibility of Co-Conspirator: Maramara's testimony was found credible. Minor inconsistencies regarding details such as the number of visitors or the meeting place do not impair credibility but indicate unrehearsed testimony. A prior conviction does not disqualify a witness or render testimony ipso facto incredible. No improper motive to falsely testify was conclusively established by the defense.
• Conspiracy: Conspiracy was duly proven by the concerted acts of petitioners before, during, and after the commission of the crime, demonstrating a joint purpose to kill the victim. Proof of a prior agreement is not required when the acts indubitably point to a joint design.
• Procedural Validity and Effect of Plea Bargaining: No procedural flaw was found in Maramara's plea bargain; Section 2, Rule 116 of the Rules of Court does not prohibit same-day plea modifications. However, Maramara's plea to a lesser offense in a separate information does not benefit petitioners, as they were not co-accused in the same information charging conspiracy, thereby distinguishing the case from People v. Tapalla.
• Proper Offense and Penalty: The crime is murder, not homicide. Treachery qualified the killing to murder due to the sudden, unexpected attack from behind on an unarmed victim. Evident premeditation was also proven and served as a generic aggravating circumstance. With one aggravating circumstance and no mitigating circumstance, the penalty of death would ordinarily be imposed, but is reduced to reclusion perpetua without eligibility for parole pursuant to Republic Act No. 9346.

• Co-Conspirator Testimony — The testimony of a co-conspirator is insufficient for conviction unless corroborated by other evidence. As an exception, uncorroborated testimony of a co-conspirator suffices if given in a straightforward manner and contains details that could not be the result of deliberate afterthought.
• Effect of Plea Bargaining on Co-Conspirators — A plea of guilty to a lesser offense by one accused benefits co-accused only if they are charged in the same information for conspiring to commit the crime; it does not extend to co-conspirators charged in a separate information.
• Multiple Qualifying Circumstances — When more than one qualifying circumstance is proven in a killing, one qualifies the crime as murder, and the others are considered generic aggravating circumstances.
• Treachery — Exists when the offender commits a crime against persons employing means that directly and especially ensure its execution without risk to the offender arising from the defense the offended party might make; a sudden attack from behind on an unsuspecting victim constitutes treachery.

• "The testimony of a co-conspirator is not sufficient for the conviction of the accused unless such testimony is supported by other evidence. As an exception, however, the testimony of a co-conspirator, even if uncorroborated, will be considered sufficient if given in a straightforward manner and contains details which could not have been the result of deliberate afterthought."
• "The information in Criminal Case No. DU-3721 indicting Maramara alone of murder is distinct and separate from the information charging petitioners for the same offense in the instant case. Moreover, Maramara was neither charged as co-accused of petitioners nor of conspiring to commit a crime in either case."
• "Inconsistencies relating to minor details do not affect the creditworthiness of the witness testifying and that minor inconsistencies tend to show that the witnesses were not coached or rehearsed."

• People v. Tapalla — Distinguished. In Tapalla, the accused who plea-bargained to homicide was a co-accused in the same information charging conspiracy, which is not the case here where Maramara was charged separately.
• People v. Mamarion — Followed. Cited for the rule that a co-conspirator's uncorroborated testimony is sufficient if given in a straightforward manner with details not resulting from deliberate afterthought.
• People v. Reynes — Followed. Cited for the rule that when more than one qualifying circumstance attends the commission of the crime, one qualifies the offense while the others are taken as generic aggravating circumstances.

• Section 2, Rule 116, Rules of Court — Governs plea of guilty to a lesser offense; applied to validate Maramara's same-day plea bargaining and to determine its effect on co-conspirators.
• Article 248, Revised Penal Code — Defines Murder; applied to qualify the killing due to the presence of treachery.
• Article 14(16), Revised Penal Code — Defines Treachery; applied because the victim was shot from behind without warning while resting inside his house.
• Article 63, Revised Penal Code — Rules for indivisible penalties; applied to impose the greater penalty due to the presence of a generic aggravating circumstance without any mitigating circumstance.
• Republic Act No. 9346 — Prohibits the imposition of the death penalty; applied to reduce the penalty from death to reclusion perpetua without eligibility for parole.
• Rule 130, Section 20, par. 2, Rules of Court — Provides that conviction of a crime shall not be a ground for disqualification of witnesses; applied to uphold Maramara's competency despite his prior conviction.

Corona, C.J., (Chairperson), Carpio Morales, Velasco, Jr., and Perez, JJ.