Alevosia was properly appreciated by the lower court. The means and methods employed in the cold-blooded killing tended directly and especially to insure its execution without risk from the defense which the victim might have made. Assailants deliberately chose the spot near the gate of Meyer Steel Pipe Corporation to ensure the murder of their quarry as the vehicles passing thereby usually slowed down due to the vicious potholes on the road. However, the aggravating circumstance of abuse of superior strength is deemed absorbed in treachery. [G.R. Nos. 112716-17. December 16, 1996]
