Case Digest (G.R. No. L-2154)
Facts:
The People of the Philippines v. Antonio Otadora et al., G.R. No. L-2154. April 26, 1950, the Supreme Court En Banc, Bengzon, J., writing for the Court.In August 1947, in the Court of First Instance of Leyte, Antonio Otadora and Hilaria Carreon were charged with the June 16, 1947 double murder of spouses Leon Castro and Apolonia Carreon. Otadora pleaded guilty on September 3, 1947, and was sentenced to life imprisonment; Hilaria pleaded not guilty, was tried separately, was found guilty, and the trial court sentenced her to death plus accessory penalties on the ground that she had induced Otadora, by promises of pecuniary reward, to commit the killings motivated by disputes over inherited property.
The factual record shows that Otadora was arrested on June 21, 1947, and on June 22 he gave an extrajudicial statement implicating Hilaria as having promised payment and supplied the weapon. A complaint for double murder was filed June 25, 1947, in the justice of the peace court of Ormoc; preliminary investigation was waived and the case was forwarded to the Court of First Instance. At Hilaria’s separate trial, Otadora was the first prosecution witness and testified to Hilaria’s solicitation, the promises of money and goods, and the furnishing of a repaired revolver and other items.
Prosecution evidence (corroborating Otadora) included testimony that Hilaria had offered increasing rewards (from P3,000 to a share of P10,000 plus carabaos and cash), that she purchased and had a revolver repaired by Benigno Baltonado (who testified to selling and fixing the gun and returning it with ammunition), and that she delivered the gun and other items (a bolo, a pair of trousers, a hat, a flashlight) to Otadora. Witnesses Amando Garbo, Juanita Garbo, Macario Bensig, Sgt. Tomada and others recounted meetings, introductions, money deliveries (including P45 delivered secretly after the crime), and attempts by Otadora to flee after notice he was wanted by police.
The defense advanced an alternate theory: Otadora had an independent motive of revenge against Leon Castro for an alleged wartime betrayal and had killed the couple on his own, possibly killing Apolonia as a witness; and that Hilaria had been framed or was merely associated through family ties. The trial judge rejected these defenses, finding Otadora’s statements corroborated by circumstances and the testimony of disinterested witnesses, and convicted Hilaria of murder, applying the qualifying circumstance of treachery and the aggravating circumstance of evident premeditation.
Hilaria appealed the conviction to the Supreme...(Subscriber-Only)
Issues:
- Was the conviction of Hilaria Carreon for instigating the double murder supported by sufficient and admissible evidence?
- Was the death penalty properly imposed, or should the penalty be modified?
- Did the trial court err in admitting and relying upon physical evidence (measuring/identifying garments) in violation of the privileg...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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