G.R. No. L-2843 - People vs Guhiting

On January 30, 1943, at approximately one to two in the afternoon, Dorotea Orillo, wife of one of the accused, Benito Guhiting, was seen running toward a guerrilla garita while shouting “Mana ya esta muerta.”
The cry set off an immediate reaction from Benito and his brother Bernardo Guhiting, along with Daniel Elandag and other members present at the garita.

The accused, Benito and Bernardo, together with Daniel Elandag, proceeded to the house of Matilde Guhiting, who was the sister of the two brothers.
Upon arrival, they encountered Zacarias, then in close proximity to Matilde’s body, seated on a petate and resting his feet on a baul. Matilde’s head lay on the ground, suggesting she was in distress with abdominal pains.

Benito was armed with a one-meter-long piece of wood known locally as “bankaro,” while Bernardo wielded a pointed bolo referred to as “buyo.”
Benito struck Zacarias with the wooden instrument on the head, right side of the face, right hip, and arms, whereas Bernardo attacked with his bolo, inflicting a cut on the region between the hand and the forearm of Zacarias.

Zacarias, found severely injured and lying on the kitchen floor, exhibited a fractured right parietal bone, broken bones in the arms, and a significant wound on the right cheek; these injuries were consistent with blunt force trauma rather than a minor defensive injury.
Testimonies from key witnesses Daniel Elandag and Alfredo Gorimbao corroborated the account of a violent assault committed with a “bankaro” and a bolo, casting doubts on the dubious self-defense version.

The defense contended that the brothers acted out of a sense of duty to aid Matilde, who was allegedly being mistreated by her common-law husband, Zacarias Murillon. It was argued that during an encounter initiated by Zacarias attempting to assault Bernardo with a scythe, Bernardo drew his bolo for self-defense, sustaining only a minor wound on his right wrist, which allegedly contributed to Zacarias’s death via hemorrhage.
Contrarily, the physical injuries observed on Zacarias—multiple severe injuries including a head fracture, shattered arm bones, and substantial contusions—strongly indicated that both Benito and Bernardo had assaulted him violently, rendering the self-defense claim unconvincing.

The incident occurred at Matilde Guhiting’s residence located in the Hubas area, barrio of Anaoaon, Surigao, which was 200 brazas from the guerrilla garita.
Additional testimonies from neighbors and acquaintances, including those of Mening (Matilde’s daughter from a previous marriage), provided support to the prosecution’s narrative, reinforcing that the accused’s actions were not in the spirit of merely offering assistance.

Whether the assault committed by Benito and Bernardo Guhiting constituted murder, given the nature and severity of the injuries inflicted upon Zacarias.
Whether the physical evidence and witness testimonies sufficiently supported a conviction for murder, despite the defense’s self-defense argument.

Whether Bernardo Guhiting’s claim of self-defense—stemming from an encounter with Zacarias—was legally tenable, especially given the disparity between the alleged minor defensive wound and the fatal injuries observed.
Whether the mistaken belief that Matilde had been “murdered” justified the brothers’ use of deadly force.

The consistency and reliability of the testimonies provided by Daniel Elandag, Alfredo Gorimbao, and other witnesses in corroborating the sequence of events.
Whether any familial or affinity relationships among witnesses could have prejudiced their testimony against the accused.