Title
People vs. Cercano
Case
G.R. No. L-37853
Decision Date
Nov 21, 1978
Four defendants were convicted of murder and frustrated murder due to a violent attack, with the court recognizing their shared accountability, the presence of treachery, and adjusting penalties for two while clarifying non-aggravating circumstances.
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Case Digest (G.R. No. L-37853)

Facts:

  • The case involves The People of the Philippines vs. Vicente Cercano, Ulen Cercano, Jose Cercano, and Bernardino Lumabao alias "Eby."
  • The accused were charged with "Murder with frustrated murder" in an Information dated October 31, 1972, filed in the Court of First Instance of Cagayan.
  • The incident occurred on July 10, 1972, in Pamplona, Cagayan, where the accused attacked Regino Bautista and Renato Mallabo while armed with various weapons.
  • Bautista was killed, and Mallabo sustained injuries.
  • Judge Arnold A. Savella, Sr. found the accused guilty on September 19, 1973.
  • Vicente Cercano was sentenced to reclusion perpetua with one mitigating circumstance.
  • Ulen Cercano, Jose Cercano, and Bernardino Lumabao received the death penalty due to the absence of mitigating circumstances and the presence of an aggravating circumstance.
  • The court ordered the accused to pay moral damages to Bautista's heirs and medical expenses to Mallabo.
  • The case was elevated for review due to the death penalty imposed on the latter three accused.
  • Jose Cercano died in prison, leaving Ulen Cercano and Bernardino Lumabao as the remaining appellants.
  • The Solicitor General recommended reducing charges to slight physical injuries, while the defense sought acquittal.
  • The court found sufficient evidence of conspiracy and collective responsibility among the accused.

Issue:

  • (Unlock)

Ruling:

  • The court affirmed the trial court's finding of guilt for murder and frustrated murder.
  • Sufficient evidence was found to establish conspiracy among the accused.
  • The court ruled that treachery was not present in the commission of the crime.
  • ...(Unlock)

Ratio:

  • The Supreme Court upheld the trial court's decision, emphasizing the evidence presented, particularly the testimonies of Renato Mallabo, which established the collective action of the accused.
  • The nature and number of wounds inflicted on Bautista indicated multiple assailants, supporting the finding of conspiracy.
  • The court clarified that a prior agreeme...continue reading

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