G.R. No. 56268 - People vs. Aranja y Arana

The case involves the conviction of spouses Gregorio Aranja y Arana and Magdalena Aranja y Ramirez for the killing of Joseph Tan.
Initially convicted of murder and sentenced to life imprisonment, the spouses’ appeal was partially withdrawn—Magdalena later withdrew her appeal—leaving the decision to address solely Gregorio’s case.
The incident is rooted in longstanding animosity between the Aranja and Tan families, with previous confrontations including litigation—such as an earlier suit over an alleged attack—and physical altercations.

On the evening of July 2, 1978, at approximately 9 o’clock, at Tomas Mapua Street in Sta. Cruz, Manila, a confrontation occurred involving Joseph Tan and associates on one side and members of the Aranja family on the other.
Details of the physical altercation:

Joseph Tan, along with his friend Lucilo Amora, was en route to a compound where the Aranjas resided.
Without clear provocation, Roberto Aranja attacked Amora by striking him in the eye, resulting in his fall.
Roberto Aranja and his father proceeded to pin down Tan’s arms.
Magdalena Aranja, present at the scene, shouted “Saksakin mo na, Raul!” which directly incited violence.
Following Magdalena’s command, Raul Nunez stabbed Tan in the stomach with a bolo, and a fifth accomplice, Prado Azurpado, struck Tan on the head with a piece of wood.
After inflicting further injuries, Roberto, Raul, and Prado fled the scene, abandoning Tan who was left bleeding and helpless.

The victim, Joseph Tan, was attended to by several bystanders who helped transport him to the Philippine General Hospital, although he eventually died three days later.

Lucilo Amora detailed the sequence of the attack and identified the involvement of each of the five assailants.
Ricardo Pretal testified that he overheard Gregorio Aranja remark, “Kung galit ka sa tao, huwag nang maraming daldal. Patayin na,” which was seen as indicative of his intent.
Bernabe Andres recounted that, shortly after the assault, Joseph Tan identified the attackers as Nunez, the Aranja spouses, their son Roberto, and a fifth individual, Prado.
Adelaida Tan, the victim’s wife, provided testimony on both the attack’s dynamics and the significant monetary and emotional losses incurred.
Zenaida, daughter of the Aranjas, corroborated the events by describing her observations during the attack, noting that she heard Tan repeatedly call out the name “Nunez.”
Benjamin Garcia testified that he saw Gregorio Aranja sleeping at the time the altercation was occurring.

Additional evidence from the autopsy confirmed that Tan sustained multiple stab and incised wounds, abrasions, contusions, and other injuries consistent with the attack.
The trial court considered that, notwithstanding some discrepancies in the witness testimonies—as might be expected in a chaotic and emotionally charged situation—the overall evidence pointed to the clear participation of the Aranja spouses in a concerted and conspiratorial attack against Tan.

The prosecution successfully established that the Aranja spouses acted in concert with other assailants.
Gregorio Aranja’s defense of alibi was rebutted by the evidence, particularly testimony indicating that he physically restrained Tan while his accomplice, Nunez, inflicted the fatal stab.
Magdalena Aranja’s direct command during the attack confirmed her involvement in the conspiracy.

The motive for the crime was primarily the enduring personal enmity between the two families.
Based on the evidence, the trial court convicted the spouses of murder, qualified by treachery, and imposed reclusion perpetua along with accessory penalties.
Monetary awards were also imposed, including compensations for death, loss of earnings, moral damages, and hospital expenses—with the civil indemnity being increased from P12,000.00 to P30,000.00.

Whether the established facts and multiple eyewitness testimonies were adequate to link the accused as co-conspirators in the commission of the murder.
The admissibility and weight of circumstantial evidence, such as the overheard remark by Gregorio and the dying declaration of Joseph Tan.

Whether Gregorio Aranja’s claim of being asleep at the time of the incident could be sustained in light of contradictory testimonies.
Assessment of the minor inconsistencies in witness testimonies due to the chaotic situation during the attack.

Whether the failure to indict the other alleged conspirators could be used to undermine the guilt of the accused-appellants.
The impact of alleged deficiencies in the prosecution’s investigation, particularly regarding the ex parte irregularities and omission of certain co-accused, on the validity of the conviction.

Whether the imposed penalty of reclusion perpetua and accessory penalties were in accordance with the gravity of the crime.
The justification for increasing the civil indemnity award, given the evidentiary and testimonial findings.