Title
People vs. Cadag
Case
G.R. No. L-13830
Decision Date
May 31, 1961
A confrontation over a hat escalated into violence, leading to Camilo Mendoza's death. Defendants, initially claiming alibi, were convicted of homicide due to conspiracy, with penalties adjusted by the Supreme Court.

Case Digest (G.R. No. L-61323-24)
Expanded Legal Reasoning Model

Facts:

  • Incident and Immediate Circumstances
    • On May 23, 1956, shortly before 9:30 p.m., Camilo Mendoza and Nicolas Yutiga, boarding with Antonio Mauleon in Masbate, left Mauleon’s store at the market place to meet arriving relatives at the wharf.
    • While en route, Mendoza accidentally stepped on a hat lying on the street. Shortly after, the group encountered the accused.
    • Leonido Cadag, one of the accused, demanded, “Primo, what are you doing with my hat?” and attempted to box Mendoza; when unsuccessful, he struck Yutiga with a fist blow.
    • Subsequently, Cadag produced his Batangas knife and threatened Mendoza, causing Mendoza and Yutiga to flee toward Mauleon’s store.
  • Escalation and Fatal Attack
    • Upon reaching the store and reporting the incident, Mauleon approached the accused, who were at some distance, but received no clear explanation from them.
    • Shortly thereafter, Mendoza, Yutiga, and Mauleon were encircled by the four accused; during this confrontation, Cadag again attacked by boxing Mendoza and then, while holding him by the shoulder, stabbed him in the neck.
    • Amidst the altercation, accomplices Dominador Arado, Bonifacio Cadag, and Antonio Gaton shouted encouragements such as “Go ahead and stab that Tagalog,” and actively participated by hurling stones and brandishing a piece of wood and a stone.
    • The assailants then chased the wounded Mendoza up to the slaughterhouse.
    • Camilo Mendoza was rushed to the hospital; his dying declaration later recounted the incident without specifically naming the assailants, and he succumbed to his injuries the following day.
  • Trial Court Proceedings and Findings
    • The trial court found all accused guilty as co-principals in the murder of Camilo Mendoza.
    • The accused were sentenced to reclusion perpetua with accessory penalties, including joint and several indemnification of the deceased’s heirs and the payment of costs.
    • The court dismissed the alibi defense presented by the accused based on clear and positive identification by witnesses.
  • Post-Trial Developments and Defense Evidence
    • During the pendency of the appeal, the defense submitted motions for a new trial supported by affidavits.
      • An affidavit by Mayor Benjamin Magallanes implicated Bonifacio Cadag and Antonio Gaton as being on duty at the pier for contraband control.
      • Leonido Cadag’s own affidavit confessed to the killing but claimed self-defense, supported by an affidavit from Teofilo Deocaresa.
    • Contradictory and weak alibi testimonies appeared for appellants Arado, Gaton, and even Cadag himself, with witness accounts failing to satisfactorily corroborate their claimed whereabouts.
    • The inconsistencies, particularly in Leonido Cadag’s testimony before and during trial, were noted as indicative of a guilty conscience.

Issues:

  • Determination of Criminal Liability
    • Whether the evidence presented sufficiently established that all accused acted as co-principals in the commission of the crime.
    • Whether the act, initiated by the accidental stepping on a hat, escalated to constitute homicide or murder.
  • Validity and Credibility of the Defense’s Evidence
    • Whether the alibi proffered by the accused, supported by affidavits and conflicting statements, could mitigate or exonerate them from criminal liability.
    • Whether Leonido Cadag’s claim of self-defense, coupled with his contradictory testimony and affidavit, was credible.
  • Existence of Conspiracy
    • Whether the circumstantial evidence demonstrated a conspiracy among the accused to inflict bodily harm on the deceased.
    • If the acts of all accused, taken collectively, reflected a common purpose that would establish a joint liability for the homicide.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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