G.R. No. L-36662-63 - People vs. Camano

On February 17, 1970, in the barrio of Nato, Municipality of Sagnay, Camarines Sur, Filomeno Camano, after consuming liquor, allegedly committed two separate killings using a bolo (locally known as “palas”) that belonged to him.
The first victim, Godofredo Pascua:

Stabbed twice with the bolo while walking near Socorro Buates’ store, sustaining a three-inch stab wound below the left axilla that penetrated vital organs including the heart, and a second incised wound at the left arm.
Autopsy findings revealed the fatal wound produced instant death due to severe hemorrhage.

Attacked at the seashore when found kneeling by his house fence, with a sequence of assaults involving hacking on the head, continued blows while he lay prostrate, and a final thrust to the chest.
Sustained eight wounds, of which two (a stab wound across the chest and a neck wound) were mortal, leading to death from severe cardiac hemorrhage.

The victims and the accused were neighbors residing on the same street in Barrio Nato.
A history of personal animosity was noted:

Three years before the killings, a fishing dispute occurred when Camano’s request for assistance in towing his boat by Pascua and Buenaflor was denied.
This refusal allegedly led Camano to harbor a prolonged grudge, as evidenced by his repeated challenges during episodes of intoxication.

Despite occasional drinking sessions with Godofredo Pascua, Camano’s friendly demeanor was described as artificial, while his overt detestation for Mariano Buenaflor was well known, including multiple failed attempts by a neighbor (Amado Payago) to reconcile the differences.

The bolo used in the killings was recovered from Camano’s house after his surrender to the police, still stained with human blood from the base of the handle to the tip of the blade.
Autopsy reports detailed the wounds on both victims, reinforcing testimonies regarding the positions and nature of the attacks.
Testimonies, particularly from neighbors and the lone defense witness Nemesio Camano (a close relative), were found to be inconsistent and lacking credible support.

After the killings, Camano returned to his house and voluntarily surrendered to the police upon their demand, though he refused to sign a statement.
In court, the accused confessed to killing Mariano Buenaflor but denied killing Godofredo Pascua, asserting that his actions were taken in self-defense amid a group assault during a drinking session.
His version of the events included a narrative of being boxed and attacked by group members and regaining possession of the bolo to defend himself; however, this was discredited by the trial court as inherently improbable and contradicted by physical evidence.

Camano was charged with murder in two separate informations relating to the deaths of Pascua and Buenaflor, with evident premeditation and treachery as aggravating circumstances alleged by the prosecution.
The trial court rejected the self-defense plea due to inconsistencies and the inability of the accused and his lone witness to provide a coherent account of the events, relying instead on the overwhelming forensic and testimonial evidence supporting premeditation and treachery.

The prosecution emphasized the existence of premeditation based on Camano’s long-held resentment and repeated threats, while the defense maintained that the killings were spur-of-the-moment and committed in self-defense.
Issues regarding the aggravating circumstance of treachery were supported by eyewitness testimony and the anatomical consistency of the wounds indicating an attack from behind, particularly in the case of Godofredo Pascua.
The element of intoxication was debated: the defense argued that it should be mitigating, claiming accidental intoxication did not facilitate a premeditated killing, while the prosecution and trial evidence showed that Camano’s occasional drunkenness did not reach the level of habitual intoxication.

Whether the accused’s actions were premeditated or resulting from a “spur-of-the-moment” reaction amid a group altercation, and if there exists sufficient evidence to establish premeditation.

Examination of the timeline and motive, particularly the alleged longstanding grudge from a fishing dispute.
Analysis of whether the killing was the result of a calculated plan or an impulsive act during intoxication.

Whether the crimes were committed with treachery, specifically concerning the method of attack (e.g., attacking from behind) and the incapacity of the victims to defend themselves.

Consideration of eyewitness testimony corroborating that Godofredo Pascua was stabbed from behind and that Mariano Buenaflor was attacked while in a vulnerable, kneeling position.

The validity of the self-defense claim presented by the accused and whether his testimony (and that of his relative witness) holds evidentiary weight sufficient to create reasonable doubt.

Scrutiny of the inconsistencies in the accused’s version of events versus the physical and testimonial evidence.

Whether the aggravating circumstances of premeditation, treachery, and abuse of superior strength are properly substantiated and whether the alternative circumstance of intoxication should be considered mitigating rather than aggravating.

Determining if Camano’s intoxication was intentional to facilitate the crime or merely incidental.
Evaluating if abuse of superior strength is a separate aggravating circumstance or absorbed under the concept of treachery.

The appropriateness of the death penalty in light of the constitutional provision against cruel or unusual punishment.

Addressing whether the severity of the penalty imposed aligns with existing jurisprudence and whether the penalty is considered excessive or justified.