G.R. No. 186420 - People vs. Anod

The case involves the People of the Philippines versus Samuel Anod, with Lionel Lumbayan as co-accused and Erlando Costan as the victim.
The events occurred on May 16, 1997, in Barangay Borbonan, Bislig, Surigao del Sur, where the accused were charged with the crime of Murder.
An Information dated June 23, 1997, charged the accused with conspiring, confederating, and mutually helping one another to kill Costan using a pointed bolo, with treachery and evident premeditation.

According to the Information, the accused attacked, assaulted, stabbed, and hacked the victim, causing multiple stab and hack wounds leading to his instantaneous death.
The charge is predicated on the alleged commission of the crime with intent to kill and the use of means (treachery and evident premeditation) that qualify the killing as Murder under Article 248 of the Revised Penal Code.

Costan was stabbed and hacked to death in his residence before midnight on May 16, 1997, with his body later discovered by Miguel Platil.
On May 17, 1997, both accused surrendered to the Barangay Chairperson of Borbonan, Andromeda Perater, and an admission of killing was recorded in the Barangay Logbook with corroboration by two other witnesses.

Appellant asserted that he and Lumbayan were involved in a drinking spree at a local store earlier that evening, accompanied by a third person named Angges.
Appellant claimed that circumstances changed when Lumbayan unexpectedly stabbed Angges and then forced him to accompany Lumbayan to Costan’s house.
At the victim’s residence, Lumbayan allegedly ordered the appellant to tie down Costan and then command him to stab the victim.
Appellant maintained that his action—stabbing Costan—was committed under duress and uncontrollable fear for his life, asserting that he acted against his will.
Lumbayan, on the other hand, denied involvement, claiming that both he and the appellant had retired early to his aunt’s house, with subsequent surrendering occurring only later at the insistence of the Barangay Chairperson.

During the arraignment on November 12, 1997, both accused pleaded “not guilty.”
On July 3, 2001, the Regional Trial Court (RTC) of Bislig, Surigao del Sur, Branch 29, found both appellant and co-accused guilty beyond reasonable doubt of the crime of Murder.
The RTC sentenced them to suffer reclusion perpetua and ordered payment of damages amounting to P50,000.00 to the widow of Costan.

The appellant challenged the RTC’s Decision by appealing, leading to the case’s automatic elevation and subsequent transfer to the Court of Appeals (CA) following the Supreme Court’s Resolution dated September 6, 2004.
The CA Decision, rendered on August 27, 2008, affirmed the RTC’s factual findings with modifications:

The penalty of reclusion perpetua was maintained (without eligibility for parole).
The damages were recalculated to award the heirs of Costan P75,000.00 as civil indemnity, along with additional sums for moral, exemplary, and actual damages.

That his acts were the result of irresistible force and uncontrollable fear—hence, exempting him from criminal liability.
That the qualifying circumstances of evident premeditation and treachery were not substantiated beyond reasonable doubt.

Whether the defense of irresistible force and uncontrollable fear sufficiently exempts an accused from criminal liability for Murder.

Was the alleged compulsion and fear so imminent and overwhelming that it left the appellant no opportunity for escape or self-defense?
Did the circumstances meet the strict requirements of Article 12 of the Revised Penal Code for such a defense?

Whether the factual findings regarding treachery and evident premeditation were correctly ascertained and legally sufficient to qualify the crime as Murder.

Were the qualifying circumstances adequately supported by the evidence, particularly given that the Barangay Chairperson’s testimony was pivotal?
Did the trial court err in its interpretation and application of treachery and premeditation?

Whether the adjustment of the awarded civil indemnity from P75,000.00 to P50,000.00 is in accordance with prevailing jurisprudence and the changes in penal circumstances (i.e., the move from the death penalty to reclusion perpetua).

Is the reduction of civil indemnity consistent with the legal principles and recent decisions cited in relevant case law?