G.R. No. L-13968 - People vs. Cortez

On January 11, 1956, an information for murder was filed in the Court of First Instance of Isabela against four accused: Alejo Uy, Sergio Pataueg, Felix Sacang, and Ildefonso Cortez, in connection with the death of Librado Pascual.
During the trial, Ildefonso Cortez was acquitted; Sergio Pataueg and Felix Sacang were convicted of slight physical injuries; and Alejo Uy was found guilty of murder, sentenced to reclusion perpetua, ordered to indemnify the heirs of the deceased with ₱6,000.00, and to pay one-fourth of the costs.
The case eventually reached the Supreme Court due to the severity of the penalty imposed on Alejo Uy.

On the night of October 24, 1955, a dance was held at the yard of Juan Saguisi in Turod, Reina Mercedes, Isabela, to celebrate his daughter’s wedding.
The event was well attended and adequately illuminated by several electric light bulbs.
A special dance number was announced by Balbino Dulay, the master of ceremonies, which involved candidates running for municipal offices.

As the dance progressed, Dulay requested one of the attendees, Elpidio Pedro, to ask the crowd to move back from the dancing area.
When Pedro attempted to clear the crowd, he was pushed back by individuals identified as Sergio Pataueg, Felix Sacang, and Alejo Uy, residents of Banquero, a barrio of Reina Mercedes.
An altercation ensued when Pataueg struck Pedro with a fist, leading to further physical conflict.

Ernesto and Remigio Pascual intervened by admonishing the three Banquero residents to cease making trouble.
A fist fight broke out between the Pascual brothers and the trio; during this melee, Dulay observed that Alejo Uy had drawn a balisong and that Sacang was armed with another weapon.
Dulay intervened by restraining the two armed men, and the fighters were repositioned to their original places, while the Pascual brothers retreated.
At the center of the commotion, after policeman Pedro Cortes fired a shot in the air, Uy, along with Pataueg and Sacang, rushed toward Librado Pascual, who was standing defensively with his arms crossed.

Pataueg clubbed Librado Pascual with a long piece of wood on the upper part of his back.
As Librado turned to defend himself, Sacang hacked him on the back of the head with a bolo.
In the ensuing confusion, Alejo Uy, advancing from the right side of Librado, stabbed him with a dagger on the right chest just below the armpit.
The assailants then fled the scene, leaving the injured Librado, who was later rushed to a clinic at Cauayan, Isabela.

At the clinic, Dr. Angel P. Albano treated Librado, noting three wounds: a deep, penetrating stab wound on the right side of the chest (fourth interspace above the nipple), a contused wound on the head, and an ecchymosis on the scapular region.
Due to the severity of the stab wound, an operation was performed.
Librado, aware of his impending death, provided an ante mortem statement to policeman Sgt. Ordonez, which was promptly typewritten and signed.
The statement detailed that Sergio Pataueg struck him with a piece of wood, and Alejo Uy stabbed him with a sharp pointed knife as he attempted to pacify the fight.

Approximately two years after the incident, Domingo Paual testified for the defense, confessing that he was the one who stabbed the deceased.
Paual’s confession raised serious inconsistencies:

His account conflicted with the physical evidence, as he claimed a backstab while Librado was facing him—a scenario inconsistent with the inflicted wounds.
He asserted that he delayed informing the authorities due to fear of reprisal, which further undermined its credibility.

Appellant Alejo Uy testified that he witnessed Paual stab Librado and even had communicated the event to the victim’s relatives, further casting doubt on Paual’s statement.
The credibility of Paual’s last-minute confession was severely questioned in light of the coherent and consistent testimonies of other eyewitnesses present during the incident.

Whether the ante mortem statement of the deceased, given under the consciousness of impending death and recorded by Dr. Albano and Sgt. Ordonez, is admissible and authentic.
The reliability of the testimonies of key witnesses, namely Jeremias Lungub, Balbino Dulay, and Gregorio Santua, in light of any potential motive to perjure.

Whether Paual’s confession, made two years after the incident and during the defense’s presentation of evidence, should be given weight in establishing the facts.
The reasons behind his delayed admission and its implications on the credibility of his testimony.

Whether the stabbing executed by Alejo Uy qualifies as murder—particularly if it was committed with treachery—or if it should be classified as homicide given the circumstances.
The significance of the victim’s state (in the midst of a melee and in a defensive posture) in determining the intent and qualification of the crime.

Whether the element of abuse of superior strength, as evidenced by the numerical and armament advantage of the aggressors against the unarmed victim, constitutes an aggravating circumstance warranting a modified sentencing.